Written evidence submitted by Greater Manchester Combined Authority (GMCA) (AAC0070)
The Greater Manchester Combined Authority (GMCA) is made up of the ten Greater Manchester (GM) councils and Mayor Andy Burnham, who work with other local services, the Voluntary, Community, Faith and Social Enterprise (VCFSE) sector, businesses, communities and other partners to improve the city-region.
The ten councils (Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Stockport, Tameside, Trafford and Wigan) work together on issues that affect everyone in the region, to improve the lives of their residents and support people to live well.
The GMCA is submitting evidence to the Inquiry into Asylum Accommodation on behalf of GM’s ten Local Authorities (LAs). We have prepared the submission and recommendations below based on consultation with local authority services (social care, education, homelessness, asylum-migration), as well as health and VCFSE partners. We hope to have accurately reflected some of the experiences of GM residents who have lived in asylum accommodation in the submission below, however we recommend the Committee proactively engage with lived experience groups to ensure that their voices are heard and recommendations considered.
Summary and Recommendations
The current asylum accommodation and support model is dysfunctional in terms of design, delivery and outcomes and in Greater Manchester, our disproportionate share of the asylum population makes the impacts of this dysfunction particularly acute. It drives homelessness and undermines social cohesion. It damages the health and wellbeing of vulnerable people by placing them in frequently overcrowded, poor-quality accommodation, with limited access to support and services, and a restricted right to work.
Overall, the asylum accommodation contract (AASC) lacks the resourcing, embeddedness with local systems and emphasis on individual wellbeing and longer-term integration outcomes to address these issues. In addition, local authorities lack the dedicated funding to manage the impacts and support positive integration outcomes.
In our submission we outline issues relating to the asylum dispersal model and the procurement, quality and appropriateness of asylum accommodation. The detrimental impact that the current asylum accommodation model has on local services, communities and individuals seeking asylum is described in detail. Key areas of concern include:
Procurement, quality and distribution of asylum accommodation
Disproportionately high asylum dispersal to GM over many years has placed significant pressures on local services and undermined positive outcomes for individuals. This is exacerbated by practices that incentivise procurement of lower-cost housing in deprived areas of existing high dispersal, often below acceptable housing standards.
Uncollaborative and inequitable approaches to procurement, combined with reliance on hyper-visible hotel sites and lack of embeddedness of asylum support providers with local systems, has exacerbated community tensions and threatened the safety of people seeking asylum residing in GM.
Asylum contingency hotels are regularly established without proper consultation or notice for local authorities and residents, leaving little time to prepare communities and mitigate potential negative impacts. Their inappropriate use, as long-term accommodation for children and adults with vulnerabilities for example, is another key concern, leading to harmful impacts on wellbeing and health.
Impact on services and individuals receiving asylum support
- Missed integration and homelessness prevention opportunities: The asylum system is one of the primary drivers of rough sleeping and statutory homelessness in GM. This is frequently driven by poor coordination between the asylum accommodation Provider and local systems, and the absence of an early integration and homelessness prevention offer for people in the asylum system.
- Health and wellbeing: Frequently overcrowded, unstable and poor-quality accommodation, a lack of food autonomy and unhealthy food in hotels have long-lasting negative physical and mental health consequences, especially for children and vulnerable adults. Stakeholders expressed concerns about unmanageable impacts on primary care services of hotel sites, and inadequate provision to prevent and manage infectious diseases.
- Safeguarding and welfare: Stakeholders report that inadequate safeguarding practices and reporting procedures mean that serious safeguarding risks or health concerns frequently go unreported to local authorities and NHS GM. Age-disputed young people presenting in hotels who are not referred to the LA are a particularly urgent concern.
- Lack of access to basic living essentials and VCFSE collaboration: Insufficient provision of essentials in asylum accommodation, eg. clothes, hygiene items and baby equipment, means that significant and sustained demand is placed on VCFSE organisations. VCFSE organisations deliver other essential services in hotels eg. English language classes and wellbeing activities, but report that they are frequently obstructed by miscommunication and lack of positive partnerships with on-site staff.
- Education: The inequitable dispersal of people seeking asylum, along with underfunding of provision, has led to unmanageable demand for adult English language classes and school placements for asylum-seeking children in some GM areas, especially around family hotels. This has led to children from asylum-seeking families sometimes experiencing periods of time without education and missed integration and support opportunities.
Managing and sharing data
Most local authorities and NHS GM receive no routine or timely notifications or information on arrivals or departures of residents in asylum accommodation. The information shared about individuals’ health and safeguarding risks is inconsistent and lacks important details which means that people miss out on essential healthcare and local authorities are unaware of disabilities or known domestic violence or modern slavery/human trafficking concerns related to the individual. Insufficient data sharing when families move-on from asylum accommodation can lead to children missing out on education as local authorities are unaware of their presence in their area.
This places people living in asylum accommodation at risk as it obscures residents’ support needs, obstructs local authorities from being able to fulfil their statutory duties and prevents local organisations from delivering essential services. The near-absence of routine data-sharing of any kind with statutory partners such as NHS GM also makes service planning and the appropriate allocation of resources impossible.
Recommendations
First and foremost, GMCA recommends that government delivers on its commitments to implement equitable and fair asylum dispersal nationally.
It further recommends reforms to the asylum accommodation contract to include:
- Greater Local Authority (LA) involvement in oversight and review and more frequent contract review cycles, so that the contract delivery of place-based and collaborative provision may be adequately assessed.
- Review of property standards (and their application in practice) including the views of people with lived experience and LA housing standards leads, in order to develop a framework in line with LA approaches and responsive to the population’s needs. Property inspection duties and sanctions could be supported by LAs, if provided with necessary resources.
- Improved engagement and collaboration by accommodation Providers with local systems and the provision of adequate staffing to do so, including in the procurement of new properties and arbitration in relation to this.
- Improved operational staff capacity for the accommodation Provider to deliver responsive, holistic housing-related support, with a programme of required training on trauma-informed practice, safeguarding and other priorities identified.
- Strengthening of requirements and protocols to ensure resident wellbeing and safeguarding, with the input of people with lived experience, LA and voluntary sector stakeholders. This should include:
- Immediate notification of LA for all age dispute cases, combined with strengthening of Merton-compliant assessments at the border.
- Publication of clear and consistent safeguarding protocols governing the identification and treatment of vulnerable individuals and timely notification of LAs.
- Requirement to retain dedicated rooms in contingency hotels for the isolation of individuals with infectious diseases; age-disputed young people; and the delivery of health, therapeutic and support services.
- No longer housing people with serious health conditions or known vulnerabilities in hotels.
- Obligatory and regular training for Provider operational and frontline staff regarding safeguarding, trauma-informed practice and Infection Prevention and Control.
- Expenses for local travel costs to support parents and children with school travel, as well as access to community-based activities that support wellbeing and integration where needed, e.g. English classes.
- Information-sharing agreements and requirements to share information at the strategic and operational levels with key statutory partners, including education, health, police and fire services. This should include:
- Routine reporting of all individual arrivals and departures at hotel and dispersal accommodation to LA and health partners, including known health and safeguarding issues.
- Notification of health and LA partners of destinations of those being moved out of area within the asylum estate, in order to ensure continuity of healthcare and to exercise the LAs duty under the Education Act 1996 to identify children missing education.
- Routine reporting of overall numbers and property locations across the asylum estate to health, police and fire service partners, in line with what is shared with LAs.
- Improved timely notifications of health and LA partners in cases where there are emergent safeguarding and/or health concerns.
- Improvement of overall standards and performance through greater penalties for non-compliance.
Improved local authority settlement for integration support
Improved outcomes depend on more effective local partnerships. Changes must be supported by an enhanced and long-term funding settlement for local authorities that facilitates direct integration and settlement support for people seeking asylum, refugees and wider non-UK national communities. This should be additional to the housing-related support provided under the accommodation contract. Funding should be at levels that offset pressures on mainstream services and enable the targeted provision that all our non-UK national (but especially our forced migrant) communities need.
Key additional policy changes which would support and enhance these options include:
- Make people in the asylum system eligible for general employment after six months of waiting for their asylum decision, and for Shortage Occupation List roles from day one.
- Make permanent the extended notice periods for eviction from asylum accommodation from 28 days to 56 days, in line with Homelessness Reduction Act duties.
- Notify local authorities of support discontinuations as a result of negative asylum decisions, in line with information received on positive decisions.
- Remove restrictions on the Adult Education Budget and uplift funding accordingly, so that people seeking asylum can access English language classes in their first six months.
This investment and reform would serve cross-Departmental priorities. Investing in local integration would support the government’s growth mission. At a time when we are seeing both a growing shortage occupation list and challenges in relation to sponsorship licensing within particular sectors, enhancing the education, work, skills and English language offer to people seeking asylum and allowing them to work after six months could:
- Unlock economic growth by ensuring people are supported into work through a support package that is relevant to their local economy.
- Mitigate the need for homelessness prevention, by ensuring people can maximise their incomes and find their own properties upon support discontinuation.
- Relieve spending pressures on both local authorities (in temporary accommodation costs) and Government (via reductions in drawdowns of welfare benefits).
In our submission below, based on consultation with voluntary sector (VCFSE), local authority (LA), health and education partners in Greater Manchester (GM) we outline some of the key impacts of this dysfunction on GM residents seeking asylum, our services and wider communities.
- Procurement, quality and distribution of asylum accommodation
Issues addressed:
- The Home Office’s approach to the distribution of asylum accommodation at a regional and local level
- How the Home Office works with other Government departments and local authorities on housing supply issues
- The Home Office’s engagement and joint working with local authorities, local health services, NGOs and other local partners
Greater Manchester is home to over 8,700 people seeking asylum living in Home Office accommodation managed by Serco (the accommodation Provider), equivalent to 13.1% of the national asylum population and 9.8% of the dispersed population (September 2024). There are 30 people seeking asylum per 10,000 population in Greater Manchester, compared to the national rate of 18 per 10,000 population. In other words, Greater Manchester is at 136% of the Home Office’s own Service User Demand Plan for the city-region, with three boroughs at over 200% of their Home Office-determined appropriate allocation (December 2024). This is despite government commitment and attempts to deliver a fairer approach to national dispersal.
Progress has certainly been made in recent months towards a more place-based understanding of appropriate dispersal levels and analysis and sharing of data across resettlement and asylum schemes. However, the pathway towards achieving a fair and place-based approach to dispersal nationally is still far from clear.
1.1 The planning and operation of accommodation procurement
An apparent lack of urgency to prioritise procurement in areas with historically low dispersal, combined with pressures on accommodation Providers to cost-save and rapidly procure accommodation, incentivises procurement of substandard, cheaper housing in deprived areas and in areas of existing high dispersal, like GM. While progress has recently been made to take better account of wider service pressures through Regional Dispersal Plans, progress is slow.
a) Contingency hotels
The lack of consideration for local feedback regarding procurement of asylum properties is especially concerning when it comes to the establishment of new contingency hotels.
Pressures and impact of contingency hotel accommodation on communities and local services are exacerbated by the manner in which the Home Office and its Provider stand up hotels – without adequate consultation or information-sharing in advance. In Greater Manchester, this has led to hotels being procured in inappropriate locations (for example with significant access barriers to essential services or community activities or with pre-existing community tensions) and left local authorities with little or no time to prepare the local community and mitigate negative impacts. In one recent case, the LA was given less than a week’s notice of people seeking asylum being moved into a hotel.
1.2 Inappropriate use of contingency hotels
The use of contingency hotels as long-term accommodation for individuals, especially for families with children and people with health-related needs, is inappropriate and leads to multiple negative outcomes for the people being accommodated. Research carried out by voluntary sector partners indicates that people who stay in hotels for long periods of time experience damaging and long-lasting physical and mental health impacts (Refugee Action 2023[1], Helen Bamber Foundation & Asylum Aid 2024[2]) face additional barriers to effectively integrating within the community and often feel stripped of their dignity and autonomy. This is exacerbated when hotels are in hard-to-reach or inaccessible locations which further segregate residents from other members of the community. There is also a lack of suitable accommodation for people with disabilities across the hotel and dispersal accommodation estate, which can result in people being unable to leave their accommodation without assistance due to accessibility issues.
1.3 Housing quality and standards
Stakeholders report that accommodation requiring maintenance is frequently left unrepaired and the mechanisms to report issues are ineffective, resulting in people experiencing long periods of time without hot water, functional cooking appliances or damp and mould.
1.4 Impact on social cohesion
Greater Manchester proudly welcomes people seeking asylum and refugees to our city-region, but uncollaborative and inequitable approaches to procurement, combined with reliance on hyper-visible hotel sites has exacerbated community tensions and at times, threatened the safety of people seeking asylum residing in GM.
Local authorities express serious concern and frustration regarding the lack of control over the location of properties procured, and the lack of transparency in processes to challenge inappropriate procurement. Even when serious concerns about community tensions in the locality are formally shared, if they are not backed by crime data they are sometimes dismissed. While a more collaborative approach appears to be being taken in recent months, this must be formalised through contractual means in order to ensure that local priorities are balanced against pressures to procure.
Acts of anti-asylum violence or threats are often triggered by the opening of new hotels, or the procurement of new dispersal properties in communities where tensions are already high. This was most acutely felt during the violent disorder in August 2024, when multiple contingency hotel sites in GM were targeted by violent groups, causing great fear and distress to residents, staff and wider communities.
Community Impact Assessments following the violence showed that hate crime and harassment experienced by people seeking asylum, refugees and other non-UK national residents frequently goes unreported. This signals the importance of engagement for education and trust-building in local services as part of a holistic integration offer for people in the asylum system – something that is currently lacking.
- Impact on services and individuals receiving asylum support
Issues addressed:
- The impact of the current approach to delivering asylum accommodation on local services
- The Home Office’s engagement and joint working with local authorities, local health services, NGOs and other local partners
- The Home Office’s approach to working with local partners to support people who have been granted refugee status and are leaving asylum accommodation
- Safeguarding and Welfare
2.1 Missed integration opportunities
In the sections below, we describe how the current approach to delivering asylum accommodation and support, which operates disjointedly from local systems and without adequate funding to support local service response, is harmful for the wellbeing and health of people in the asylum system, driving homelessness, and putting vulnerable adults and children at risk. GM’s disproportionate share of the national asylum population, concentrated in areas with lower-cost accommodation, has driven frequently unmanageable pressures on statutory homelessness and rough sleeping services, children’s services, schools, health services, and adult education, as well as voluntary sector services.
Taken together, this represents a missed opportunity for homelessness prevention and integration. The lack of emphasis on early engagement and support for people waiting on their decisions means increased costs to the local authority and reduced opportunities for skills-building and employment.
2.2 Homelessness and transitions from the asylum system
Having been prevented from working throughout their asylum claim, too many new refugees are evicted from asylum accommodation into homelessness. In Greater Manchester, uncoordinated exits from the asylum system are one of the primary drivers of homelessness and recent increases have further exposed the lack of integration of the asylum accommodation model with local services. This affects Greater Manchester disproportionately compared to other regions because of our disproportionate share of asylum dispersal, among other factors.
Following the Home Office’s accelerated asylum decision-making programme, we saw a thirteenfold increase in the number of asylum-leavers sleeping rough on the streets of Greater Manchester in December 2024 – over one third of our total rough sleeping population. Since then, decision numbers have stabilised and reduced, and between June-November 2024, 6% of people seen rough sleeping had left asylum accommodation in the last 86 days. This compares with a national average of 2% (June-Sept 2024) and shows that even at stabilised levels, the asylum system is still a 
significant and consistent driver of rough sleeping in our city-region.
Pressures on statutory homelessness and temporary accommodation are also acute and show signs of increasing over time. Greater Manchester saw a 360% increase in households owed homelessness duties due to eviction from Home Office accommodation in the last year. Households owed a duty due to leaving Home Office accommodation accounted for 8% of all those owed a prevention or relief duty in the quarter ending June 2024, following a peak of 14% in December 2023.
At the same time, over the past four years, the number of households in Temporary Accommodation (TA) across Greater Manchester has increased by 71% (compared to the England increase of 26%), reaching 5,649 households on the last day of March 2024. Of all new TA tenancy starts in GM between Jan-Sep 2024, an average of 14.9% were owed to households where the lead applicant had an asylum background.
Behind these homelessness numbers were many people who, despite living here for many months or years, lacked understanding of the reality of life in the UK, struggled to speak English and had little trust in public services. The impact of the absence of a meaningful early integration offer, along with a parallel accommodation system with limited local oversight, was clear.
2.3 Health and wellbeing
The damaging impact of asylum accommodation on people’s health and wellbeing is well-documented and places additional pressure on local healthcare services in the medium to long term. Frequently overcrowded, unstable and poor-quality accommodation, lack of food autonomy and limited, unhealthy and culturally inappropriate food in hotels have long-lasting negative physical and mental health consequences. Long-stays within hotel accommodation exacerbate these negative impacts, especially for those suffering from long-term health conditions or pregnant women and mothers with newborns. Health stakeholders note that the lack of access to healthy finger food throughout the day is a particular challenge for weaning babies and children.
Stakeholders report that wellbeing is also undermined by a lack of trauma-informed approaches by Provider staff and no-choice moves across the asylum estate. Obligatory moves to asylum accommodation in different areas limits residents’ ability to integrate within communities and feel settled, as well as disrupting attendance of English classes and other activities.
a) Infectious disease prevention and control
Hotel accommodation with multiple adults sharing rooms increases the risk and severity of outbreaks of infectious disease. This is further exacerbated by the continual churn of arrivals and departures through hotel sites. Frequently, spare rooms to isolate infected patients or for the delivery of health or therapeutic sessions are not available and should be made a contractual requirement.
Recently, Greater Manchester hotels have experienced outbreaks which have required considerable monitoring and oversight from LA and NHS teams to manage and bring under control. Public health stakeholders express concern regarding Provider understanding of infectious disease risk and preparedness to implement Infection Prevention and Control protocols in hotel accommodation. Additional concerns were expressed regarding the lack of routine screening for infectious disease, which is often hampered by the lack of timely data-sharing regarding new arrivals with health partners.
b) Primary care impact
The impact of asylum accommodation on the capacity of primary healthcare services, such as GP’s and dentists, is considerable, with some GP practices frequently struggling to register all new residents in a timely manner. This is more challenging in sites without on-site primary care provision. The high levels of churn of people moving in and out of contingency hotel accommodation mean that GP efforts to register patients can be negated as they quickly move out of area. This can result in patient care being interrupted, and efforts must be made by GPs to ensure that prescriptions are arranged and continuity of care is established in the receiving local authority.
2.4 Safeguarding and welfare
GM stakeholders report that the high turnover of Provider staff, poor application of existing policy and inadequate training of frontline Provider staff on safeguarding and trauma-informed practice results in poor-quality support being provided to hotel residents, inconsistent reporting of safeguarding incidents and risks, and serious safeguarding concerns being missed. This has been especially noted in hotels, but it is important to note that residents of dispersal accommodation are inherently more isolated and therefore missed safeguarding or health issues are less likely to come to the direct attention of authorities.
Health and social care stakeholders in Greater Manchester report that residents with long-standing needs or vulnerabilities are often overlooked and established policies that should ensure that people are brought to the attention of the local authority, or to the Provider’s off-site safeguarding team, are not followed. Stakeholders reported an apparent “desensitisation” of Provider staff in hotels, resulting in people with significant mental health concerns and families with specific health requirements being unable to access the support they need. In one case highlighted by a local authority, a person who had suffered from a significant brain injury had been staying in the hotel for six months without any health professionals being aware that he was there.
The lack of safeguards and assurances to ensure the welfare of people within the system has also resulted in people being dispersed from contingency hotel to dispersed accommodation without access to financial support established, meaning that they were unable to buy food and did not know any community support groups available in the area they were dispersed to.
a) Age disputed young people
The treatment and safeguarding of age-disputed young people in hotels are a particular concern. Home Office age determinations at the border are often brief, misleading and inadequate. However, when a child identifies themselves to the Provider in an adult hotel, current policies and protocols mean that the local authority is frequently not notified. Too often, GM LAs rely on referrals from VCFSE organisations working within hotels to identify age-disputed individuals, many of whom are assessed to be children and taken out of the adult hotel and into appropriate care. The retention of separate bedrooms within hotels for the accommodation of age-disputed young people should be a contractual requirement, as should the notification of local authorities of any age dispute cases.
2.5 Lack of access to basic living essentials
Home Office providers routinely and consistently rely upon unfunded VCFSE organisations, faith networks and volunteer-led community groups to provide basic living essentials to people under the care of the Home Office. This includes clothing, toiletries, mobile phones, sim cards and sanitary products for new arrivals at hotels, as well as safe sleeping equipment and moses baskets for newborn babies. Most recently, the Provider has been unable to provide sufficient essential winter clothing for new arrivals in GM and local organisations and community groups have had to plug the gap.
2.6 Education
The current inequitable dispersal of people seeking asylum, along with underfunding of provision, has led to unmanageable demand for adult English language classes, as demonstrated through long waiting lists for accredited ESOL courses in many Greater Manchester local authorities. Schools near contingency hotel accommodation are also placed under considerable pressure and are not always able to take on more students, which means that children from asylum-seeking families sometimes experience periods of time without education which is damaging for their personal growth and development, mental health and integration prospects. Travel costs for local public transport often act as a barrier to people attending education provision, especially in more isolated areas.
2.7 Voluntary sector engagement and joint working
Local VCFSE organisations are core partners in the delivery of services within hotel accommodation in GM, but their ability to effectively do this work hinges on effective and clear communication from the Provider, and a willingness for pragmatic cooperation from on-site operational staff.
Fundamentally, this represents a missed opportunity to deliver a cohesive support offer for residents, by making the most of the strengths of Home Office Providers and local specialist organisations. Voluntary sector organisations in GM report that their work in hotels is often obstructed by disjointed communication and misunderstandings within Provider staffing structures, and between local partners and on-site Provider staff. This frequently impacts delivery of services requested by the Provider eg. clothes distribution, English language classes and wellbeing activities. This is despite reported positive relationships with Provider regional partnership staff, and prior agreements on the delivery of services with other Provider staff.
- Managing and sharing data
The disjointedness of the accommodation (AASC) Provider offer from local mainstream systems is exacerbated by the lack of adequate or timely information-sharing with local partners. This creates obvious risks to individuals and obstructs local authorities’ ability to fulfil statutory duties to children in education and vulnerable children and adults (Education Act 1996, Care Act 2014 and the Children Act 1989).
Local authorities and NHS GM receive no routine or timely notifications or information on arrivals or departures of residents in dispersal or hotel accommodation. In cases where there is a health need or safeguarding issue, LAs should be notified but this is inconsistent and insufficient (as described below).
At every stage – including discontinuation of support notices - where individual-level data is shared with the LA, it is insufficient to determine their support needs, unreliable and partial. This leads to children missing out on timely enrolment into schools, people missing essential healthcare and local authorities being unaware of disabilities or known domestic violence or modern slavery/human trafficking concerns related to the individual.
For health and education services in particular, Provider inability to share the destination of people who are being moved within the asylum estate makes it impossible to ensure continuity of healthcare and schooling and increases safeguarding risk. In one representative case brought to the attention of the GMCA, a newborn baby and new mother missed out on critical healthcare appointments after they were moved from asylum accommodation in one local authority area to another and the receiving local authority was not informed of their circumstances.
In addition to individual risks created, the near-absence of routine data-sharing with statutory partners such as NHS GM makes service planning and the appropriate allocation of resources to ensure adequate healthcare access impossible. Currently, healthcare services in Greater Manchester are not permitted to know the location of dispersal accommodation in their localities, and therefore are unable to work with local GP practices to ensure provision.