Written evidence submitted by the Almshouse Association [RSH 021]
The Almshouse Association (TAA) is the membership body for the approximately 1,700 almshouse charities across the UK. For 75 years we have provided guidance and support to our members to ensure that they provide the highest level of support to their beneficiaries, continuing the ethos which has stood the test of time for the last 1,000 years. A recent report independent report commissioned by The Almshouse Association and written by Housing LIN, which can be found here, shows the benefits that almshouse provide to their communities and beyond. We are submitting this evidence as we feel that the current regulation process is not proportional to almshouses, which in turn is affecting the ability of almshouses to create more dwellings.
Almshouses have a unique legal status as confirmed in 2018. They are regulated by the Charity Commission and overseen by locally appointed representatives who have legal personal responsibilities in running almshouses properly. Furthermore, they benefit from the oversight and support of TAA, particularly the advice given in The Standards of Almshouse Management (SAM). Through SAM, members have the standards that they are expected to follow, and guidance on how to achieve them. SAM covers all areas of good governance such as financial, residential and accommodation management. It has previously been the case that SAM was verified by the former Homes and Communities agency this allowed for a shared understanding of what constituted good governance within an almshouse.
We are proud of the work our members put into ensuring that their dwellings are maintained to a high standard and so we have no major concerns over the quality of our housing. Through their Weekly Maintenance Contribution (almshouse rent) they ensure that sufficient funds are reserved for maintenance and upkeep of the dwellings. This means that all funds raised go towards the running of the almshouses and ensuring they remain in good condition.
However, as many of our members are managing historic and listed buildings this task is not easily achieved. TAA offers support including loans and grants to ensure that our members are supported in making necessary adjustments. However, more needs to be done to support charities to access funding to make these adjustments, particularly listed buildings which are being used as homes. This largely concerns informing conservation officers and local planners so there is greater understanding on the unique ways in which almshouse charities operate, in turn leading to greater cooperation. This issue is likely to grow in significance as a result of the push to retrofit dwellings.
TAA is encouraging its members to consider green alternatives when building new or refurbishing/retrofitting their dwellings. Yet, the significant costs associated with this means that these charities will not all be able to meet the challenge without significant support. TAA cannot provide this support on its own. Government must produce a long term vision for retrofitting with suitable funding to meet the challenge. This funding should look to provide specific support and guidance to properties which are ‘hard-to-treat’ such as listed buildings. This is particularly important should energy efficiency be included in the amended Decent Homes Standard.
Additional support is available for remodelling/refurbishment through the Affordable Homes Programme, however, this is where regulation can make the situation harder for almshouses, as only 300 of our members are dually regulated by the RSH and the Charity Commission. This means that the number of members who can access the Affordable Homes Programme, and other funding schemes, is restricted. This is not due to an unwillingness to engage with regulation but due to almshouses already being regulated by The Charity Commission. For many almshouse charities, run by volunteer trustees and operating on fine margins, additional regulation from the RSH is a burden that would have a detrimental impact on the viability of small almshouse charities.
Furthermore, there is a financial impact of registration which disproportionally affects almshouses which tend to be smaller providers of housing. The cost to register is £2500 and £300 a year for those with less than 1000 units. This means that a provider with over 1000 units would pay £5.56 per unit. This compares to £10.35 per unit for our members who are RPs and have an average of 28 units.
As such, we believe that regulation of almshouses through the Charity Commission should be recognised as sufficient to allowing greater access to funds for almshouse charities. This would allow for regulation and proper maintenance of the almshouses whilst respecting the supremacy of charity law and the role of the Commission in charitable matters. Moreover, this process would also allow the regulator to focus on the larger housing associations with over 1,000 dwellings or other newer providers for which this was established. We do not believe that almshouse charities, 80% of which have less than 20 dwellings, should be treated in the same way as a large housing association.
Currently, almshouse charities do not need to be registered to access Home England funding for the purpose of remodelling. This has been a vital source of finance which has allowed greater expansion and improved provision within the almshouse movement. We believe that this model, where a specific exemption has been given to almshouses, can provide a template for how funding should be granted for new build dwellings. Access to greater grant funding would enable greater capacity to build when compared to charities working independently, for example, seeing 4 new dwellings being built with grant funding instead of 2 if undertaken using their own resources because they are not registered. Many almshouse charities are already in possession of significant plots of land which could be brought forward, but they are limited by the inability to access funding from Homes England without registration. Correcting the disproportionate impact of registration on almshouse charities is vital to ensuring they can make the most of their potential and contribute to the government’s housing targets. Furthermore, the almshouse model is specifically suited to housing older people and providing homes in rural areas. As 20% of the Affordable Homes Programme must be used for these two types of dwellings it seems sensible to make it easier to bring these dwellings forward.
On this basis, we do not believe that all providers of social housing should be required to register with the regulator and that instead a more tailored approach would see better results. We believe that regulation of the almshouse sector should remain solely with the Charity Commission and that this should be recognised as sufficient for accessing funding through schemes such as the Affordable Homes Programme. This would provide more appropriate oversight of the movement and free them to explore the expansion of this genuinely affordable form of housing.
Alternatively, we would seek to revive the previous relationship between the Regulator and The Almshouse Association with regards to The Standards of Almshouse Management. Verification of SAM and associated policies could be approved by the RSH. When an almshouse charity is able to provide proof of compliance with these approved policies they could then move onto a more tailored, streamlined registration process. This would ensure that charities are exhibiting good governance, whilst providing security to the Regulator that the regulatory standards are being achieved.
TAA would be happy to provide oral evidence as part of the committee’s ongoing inquiry on this matter.