Written evidence submitted by Crawley Borough Council [EXA 002]

1. What is the quality of exempt housing provision?

Variable in our area – there are some good examples that the Council is involved and reflects the support provided e.g. homeless and young person’s accommodation.  Some where there is doubt about the level of support being provided for the costs charged and some that the Council is not involved with or aware of in terms of the support and standard of accommodation being provided, but is unable to claim back full HB subsidy as the provider is not a Registered Provider and is well above the rent officer level.

2. Is the current model of exempt accommodation financially viable, and does it represent value for money?

Where the properties are leased by private equity companies to the landlord, the core rents are very high and the standard of accommodation and support is not known to the Council, so difficult to evaluate if they provide value for money.  We are a two-tier authority so some provision and interaction may be on health and social care provision.

3. Are there significant geographical and regional differences in the provision and the problems of exempt accommodation?

Our immediate area is very small and compact but costs in the South East are very expensive and likely to vary geographically and be cheaper along the coastal area.

4. What is the proportion of exempt accommodation that is provided by registered compared to non-registered providers, and is an appropriate balance being struck?

It is fairly well balanced in our area in terms of bed spaces.  It is very noticeable that non Registered Providers have significantly higher rents as the same funding streams are not available to them so having to turn to private equity provision. 

5. What is the proportion of exempt accommodation provided by commissioned compared to non-commissioned providers, and is an appropriate balance being struck?

We are a two-tier authority so not always aware what has been commissioned and by whom, particularly in relation to health and social care services that we do not have nomination rights to.

6. How does whether a provider is registered or non-registered, or commissioned or non-commissioned, impact the quality of provision?

Difficult to comment – it is clear it impacts the cost but the quality of the accommodation will sit with the Commissioner which is often not the Local Housing Authority.

7. How should exempt accommodation be provided and what should the service cost?

There should be some sort of guidance to ensure both costs are reasonable and the quality of the accommodation is high as the legislation and case law for Housing Benefit purposes is ambiguous.  HB Teams need both resources and guidance to challenge where there are concerns and it is not our specialist area or where a service is not commissioned and we do not have access or information readily available to challenge.

8. How should the regulatory oversight of exempt accommodation be organised?

In a way that Charities can still operate and provide competitive services and good quality services despite not having the same access to funding and to challenge non-commissioned services providing poor and expensive accommodation.  There should be a minimum and clear standard that is regularly checked and monitored – similar to HMO’s that are subject to minimum standards, visits, licences and enforcement where necessary.

9. What should be the regulations governing exempt accommodation and how should those regulations be enforced?

As Above.

10. Is there sufficient publicly available information about exempt accommodation?

No, because of the enquiries we receive from organisations wanting to enter the market with the expectation to make good profit and there is no requirement to be commissioned so no oversight and monitoring being carried out until something has gone wrong.  There needs to be more help available to bring standards up and keep costs reasonable e.g. good practice guidance.

January 2022