Written evidence submitted by Voluntary Organisations Disability Group (VODG) [DPH 040]

About us 

Through the contribution of our members, VODG forms part of a community of more than 145 values-based organisations that play a vital role in supporting more than a million disabled people to live full independent lives. 

Membership of VODG is open to registered charities and not-for-profit organisations that provide services to disabled people, including registered providers of housing and those organisations delivering care and support. Our members’ work is focused on enabling disabled people of all ages to live the lives they choose. 

VODG welcomes the Committee’s focus in this area and the opportunity to submit this response, informed by the experiences of our member organisations. We have engaged widely with our membership including focused conversations across our finance and housing networks. This submission brings together their views, experiences and suggestions for change.

Response

As the Committee will be aware the importance of good housing cannot be under-estimated to a person’s health and wellbeing[1].

Despite many of the issues around quality and access to housing being well documented[2], very little progress has been made by the government, local authorities or developers when it comes to improving the experience of disabled people seeking to live as independently as possible.

Disability Rights UK call the housing sector ‘a dangerous mess for disabled people’[3] due to a range of issues including inaccessible properties, poor behaviour by landlords and poor-quality stock.

As well as a lack of good quality or affordable property, disabled people continue to face extra costs linked to specialist equipment, everyday essentials and energy[4].

It is vital for the government, local authorities, housing associations and developers to work together with disabled people to address their needs, to reduce the current challenges within the system and expediate the changes needed to enable disabled people to live how and where they want. 

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

It is imperative that the government acknowledges the pivotal role of housing and creates a more comprehensive and integrated national and local planning policy framework for supported housing with disabled people being central to this these plans. Accessible housing is good for everyone, and all of us will need adaptions to our homes to accommodate our changing needs over the life course.

The government should acknowledge the impact and importance of ensuring the right home for disabled people and the need for quicker and less bureaucratic ways of accessing grants for third sector care providers to buy or lease housing stock, and for the adaptations needed to ensure it is fit for purpose. The lack of supply of housing, particularly affordable and accessible housing for people with a disability, is a problem across the country and needs strategic oversight beyond one government Department or local authority. We hear of innovative designs and plans that providers invest in and put to developers – including smart homes – but which developers are reluctant to embrace.

There needs to be better understanding of the full scale of the issue. When the demand is fully understood, it is more likely that providers and developers can work together to deliver an accommodation specification that is both innovative and adaptable for individuals with disabilities. It is the role of government to facilitate our ability to provide the right homes for people and ensure that the NPPF is fit for purpose. 

Housing Benefit payments are not keeping up with private rental expectations and are leaving disabled people unable to rent and/or move into more appropriate homes better suited to their needs. The government should ensure those in receipt of Housing Benefit are not disadvantaged or left in a precarious position when it comes to safe, appropriate and secure housing. VODG members who support disabled people to access Housing Benefit are finding the application process is becoming increasingly and unnecessarily detailed and slow, adding further stress to an already pressured system.

We would recommend a cross-government commitment involving disabled people’s organisations, the Treasury, Department for Levelling Up, Housing and Communities, the Department of Health and Social Care, NHS England, local authorities, Integarted Care Systems, developers, private and third sector providers is needed if there is to be a real step change in the current situation, which is failing to keep up with demand.

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

The incorporation of inclusive design with the NPPF is a positive step in ensuring that buildings and the built environment are accessible to all, including disabled people. Our assessment is that it is unclear if this is having a positive impact in the delivery of housing. We have yet yet to see a marked increase in the right kinds of accessible and adapted properties within the market. 

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

The lack of supply of appropriate and affordable housing to rent or buy is having a significant impact on the lives of disabled people. It is reducing opportunities for disabled people to live independently, stalling the building the right support agenda and curtailing disabled people’s right to live the way they choose. This is in part to a lack of strategic planning by commissioners of current and future demand.

Specific actions we would like to see government, local authorities and developers take include:

• A greater level of grants should be made available to help speed up development of new properties for disabled people. This includes grants to help third sector providers and others to invest in property and to make the adaptations needed to ensure it is accessible over the life course.

• Steps must be taken to build more consistency across local authorities for people applying for accessible council and housing association homes. Currently the system by which to apply for housing or adaptations vary. Commissioning models also vary, with some focusing on very specific models of support, often focused on low level need, leaving many with more complex needs without a clear path towards their own home. 

• The process of adaptations needs to be sped up, as this can currently take months to be completed. 

• Ensure more accessible properties are being built and made available to those who need them, so there is more of the right kind of properties in the right places. Despite accessibility standards published last year[5], ‘outside London, under a quarter (23%) of new homes due to be built by 2030 are planned to be accessible’.[6]

• Local authorities must further recognise the importance of housing to a person’s health and wellbeing, using their role as ‘place leaders’ to develop solutions to the housing shortage. This includes being realistic about demands, flexible in their approach to commissioning, working with providers to find person-centred solutions and commissioning health and care together, supported by greater access to appropriate housing that meets current and future demand.

• Some local authorities understand the importance of housing and have longer-term plans to bring this to the fore. This good practice needs to be shared and built upon by other areas where plans are lacking.

• Helping people to access the homes they need requires a different approach to risk between providers and commissioners, with risk increasingly placed largely on the provider. Members reflect that tenders to provide care and support are increasingly coming with a requirement to also provide housing, and to have that available within a short period (for example three months), which is extremely challenging for care providers to realistically deliver.

• It is important for risk to be shared across partners, and a further concern is local authorities unprepared to share risk, and this can mean that some viable housing and support schemes for disabled people do not go ahead. Further, the restrictive social care contracting environment curtails innovation and development. For example, a five-year property contract coupled with only a one-year care and support contract can question the viability of schemes.

• Full repair leases and overly complex contracts are also deterring engagement by providers, with some giving services back due to costs. Developers are also stepping away from building accessible homes due to costs and reducing margins.

• There needs to be better use of existing property and support from the government and local authorities to make this fit for the future. There is often an expectation that third sector care providers will do this which is unsustainable.

• It would appear that many Integrated Care Systems (ICS) do not wish to address housing matters, despite the interdependencies of housing on health and social outcomes. The roles and responsibilities, and ways of working across all partners in local systems must include a direct focus on housing.

Does the Disabled Facilities Grant (DFG) fully support housing adaptations?

Evidence from our members suggests that the DFG is an inflexible, slow and complicated process. Claims can take a long time to be processed and often focus on short term adaptions rather than the longer term, future-proofing needed to maximise people’s support over the course of their lives.

DFG can also only be accessed after a person moves into a property, rather than helping to ensure that property is right for them from the start. Without alternative funding for this, it means disabled people face either inappropriate housing, and long waits for changes to be made, or no property at all. 

There needs to be a less bureaucratic and quicker way to access funds. In some of our members’ experiences with DFG, they have had to wait up to 12 months to access funds for works.

Providers supporting disabled people must indirectly apply for disabled facilities grant as the scheme is based on individuals. The process is cumbersome and requires access to reports, such as occupational therapy reports, which are difficult to readily obtain. Also enabling support organisation to apply on behalf of an individual may provide a more effective means of administration.

How can the Government ensure it provides sufficient provisions to support disabled residents, including private renters? 

In order to provide sufficient provisions to support disabled people, there needs to be a recognised national standard. This standard should detail what housing rights and options disabled people are entitled to across provision and should be inclusive of general housing. Local authorities meet this standard where they are paying for housing (even in private rentals) and progress against the standard should be monitored.

Although landlords should make sure properties are safe and in good condition[7], not all people renting know about the role and responsibilities of landlords or how to ask for repairs to be made. For example it does not appeaer that Government’s mandatory ‘How to rent’ has been produced in accessible versions to meet even basic accessible standards[8].

Due to the complex network of those involved in providing property solutions, it is often hard to know who to ask for help when problems arise. Roles and responsibilities should be more transparent, with specific support made available in all councils, and across the housing sector including with landlords, to support disabled people who are renting, to know their rights and the responsibilities of their landlords and how to challenge these if issues arise.

The lack of funding for social care has created unviable local care markets. This means that in some part of the country there are ‘no go’ areas where providers will not invest in services, and properties.

Building the right support

Government is committed to its ‘building the right support’ programme[9]. This seeks to strengthen community support for people with a learning disability and autistic people, and reduce reliance on long-stay inpatient care. VODG members are experienced in this reprovision however, there are specific housing challenges for this group that remain critically unresolved[10].

We are finding that the lead time for obtaining housing for people being discharged from long-stay provision is considerably longer than the lead time for putting in place care and support and staff. There are many issues around capital and revenue funding, availability, potential local objections and risk management. These challenges present an incentive for commissioners to select providers who already own or have available premises and this can reduce the pool of providers able to support reprovision.

The housing aspects to delivering building the right support requires each person to have a personal plan for discharge from early in their placement even if they will not be ready for discharge until much later and – crucially – for this plan to include a housing specification and a housing plan. Specifically for ICS and local authorities it is important for local areas to identify routes to obtaining suitable housing for health, care and support need which is not dependant on a particular choice of provider. 

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VODG is happy to prepare briefings or address further questions as the work of the Committee progresses.

September 2023

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