Written evidence submitted by Dr Chris O’Leary [EXA 001]

My name is Dr Chris O’Leary. I am an academic based in the Policy Evaluation and Research Unit at Manchester Metropolitan University. My research includes policy analysis, evaluation, and evidence synthesis. My research is focused on homelessness, particularly the effectiveness of interventions in reducing or preventing homelessness, and also addressing the harms associated with homelessness. I also work my broadly around housing need.

Before I entered academia, I spent many years working in policy evaluation and research. During the period 2002 to 2010 I led a number of pieces of work for government around the Supporting People programme. This work included the then Office of the Deputy Minister’s own review of the Transitional Housing Benefit scheme and the errors made in estimating the size of government spending on housing related support, work to estimate the financial benefits of housing related support, and also an empirical investigated of the extent of cost shunting by local authorities. I also led the development of the resource allocation formula used to allocate Supporting People funding to local authorities. I also undertook research for a number of local authorities on need for housing related support, and completed a piece of research on need for supported housing in London for the Mayor of London (O’Leary, Goldup and Rogers, 2007).

Viability of current model

The current ‘model’ is not fit for purpose. Since the current Housing Benefit exemption regulations were introduced in 1996, there have been at least three periods of substantive growth in this type of accommodation, of which the growth seen since 2015/6 is only the latest. The introduction of the Supporting People programme by the previous Labour government was intended to place all supported housing and housing related support services on a proper basis, funded through central government revenue grants to local authorities and through local authorities’ commissioning and regulating services based on local need. Over the past twelve years (and particularly the last five), it appears that this system has all but broken down and we have in effect reverted to the position pre-2003.

The current ‘model’ has significant faults:

1. Many individuals living in this type of accommodation have significant housing, support, social care, and health needs. Research from 2010 (Booth, Baker and Wilkinson, 2010) would suggest that a large number of people with learning difficulties, recovering from problematic substance use, or escaping domestic violence.
2. Many individuals are currently housed in this accommodation, without any clear understanding of their needs, support plans, how this type of provision relates to their wider social care needs, and any clear understanding of how this enables independent living.
3. It is challenging for commissioners, funders, DWP and LULC to understand how costs of support versus housing management/accommodation costs break down, or indeed to keep a control on costs. While my previous research for the then Office of the Deputy Prime Minister in 2005 did not find any evidence of substantive cost shunting (that is, using Supporting People funding on other services), it is not clear to me whether this is still the case, and more research is needed in this area.
4. While local authorities and others have powers and duties that could be used to improve access to, and quality of, exempt accommodation, it appears that many do not use these. I question whether there is sufficient funding in place, and whether there are sufficient incentives for, local authorities to more robustly use these powers.
5. The use of non-commissioned exempt accommodation, particularly in the long term, is simply not acceptable. Individuals should expect to have their needs properly access by their local authority, appropriate plans in place to meet these needs, and decent quality accommodation that enables to maximise their independent living.

Geographic differences

All things being equal, one would expect there to be geographic differences, reflecting both differences in prevalence/need, different local authority strategic priorities, but also because of related service provision.

Unregistered versus registered providers

I am not aware of any robust research around whether differences exist in the quality and value for money of unregistered versus registered providers. Assuming there are such differences, changes could be made to the 1996 regulations in terms of eligibility for exemption for local housing allowance rates – this would significantly increase regulatory oversight, though would have to be phased in over a couple of years to prevent harms caused by providers leaving the market.

Commissioned versus non-commissioned

The use of non-commissioned exempt accommodation, particularly in the long term, is simply not acceptable. Individuals should expect to have their needs properly access by their local authority, appropriate plans in place to meet these needs, and decent quality accommodation that enables to maximise their independent living.

How should exempt accommodation be provided?

Assuming for a moment that the government does not intend to make substance changes to Housing Benefit, or how HB is differently organised between social and private rented sectors, or to make changes to the Local Housing Allowance.

At the very least, the support element of exempt accommodation should be commissioned by the relevant local authority and be subject to assessment and quality controls. Indeed, I would suggest that both the housing and support parts of this type of accommodation should be commissioned. Local authorities would then be in a position to ensure this type of provision meets minimum standards.

Regulatory oversight

It should be borne in mind that local authorities already play a significant role in this type of accommodation, not least because they make Housing Benefit determinations. It is also the case that the 1996 regulations restrict exemption eligibility to non-profit organisations. More needs to be done to improve the use of these current powers.

The Regulator of Social Housing is ideally placed to provide assurance in terms of registered providers. I am not aware of any robust research around whether differences exist in the quality and value for money of unregistered versus registered providers. Assuming there are such differences, changes could be made to the 1996 regulations in terms of eligibility for exemption for local housing allowance rates – this would significantly increase regulatory oversight, though would have to be phased in over a couple of years to prevent harms caused by providers leaving the market.

Available information

The simple answer to this question is no, there is a significant deficit of information available, both for funders/commissioners/policy makers but also for service users.

Indeed, we appear to have lost considerable insight that was previously available under the Supporting People programme.

January 2022