Written evidence submitted by Anglia Revenues Partnership [EXA 014]

• What is the quality of exempt housing provision?
• The tenancy and accommodation agreements which the Council receives appear to offer a high level of support and a good standard of maintenance. Our perception however is based on the level of charges and a breakdown of services provided. There is an increased use of either concierge charges or enhanced management support which appears to support the customer with housing related matters.

As a District Council we request details for the type and level of support provided however this not usually verified by a visit to scheme. It is difficult to make any definitive conclusions with regards to the quality of accommodation provided.

• Is the current model of exempt accommodation financially viable, and does it represent value for money?
• In our experience there are many excellent schemes that provide a bespoke service to vulnerable clients. Some providers however are seeking to maximise the amount of Housing Benefit payable by engaging private consultation firms. This is a concern as each year there are substantial accommodation charge increases because of these consultations. Any increased charges are scrutinised and challenged but it is very difficult for Councils to restrict these accommodation charge increases. Consultation firms can have deleterious effects on the accommodation charges in an area leading to accommodation charge inflation. This is turn has an impact on value for money both at national and local level. Many of these increases relate to service charges. It would be helpful if eligible service charge accommodation increases were limited by regulation to help prevent the increasing cost of exempt accommodation

• Are there significant geographical and regional differences in the provision and the problems of exempt accommodation?
• Yes. As a partnership of Councils, we have found that the provision and problems of exempt accommodation does vary. The standard accommodation does not appear to be an issue.  Exempt accommodation is reflective of rent levels in the area. Accommodation charges should reflect the actual costs, which will usually be higher than for general needs housing. In higher rent areas exempt accommodation generally has very high levels of accommodation charges which far exceeds BRMA levels. In our experience accommodation in these more expensive areas is frequently provided by charitable organisations. These providers tend to be smaller with higher costs. These costs are reflected in each schemes’ accommodation charges. Most of these organisations provide an excellent service to the area, however Councils are financially penalised by the subsidy rules in relation to charities. Councils are obligated to refer claims to the Rent Officer and subsidy is limited by this decision. As these charities have high accommodation charges the council’s general fund subsidises this cost of accommodation provision. Even if there is need in the area for supported accommodation it becomes a financial liability for the council if such accommodation is provided by a charity.

• What is the proportion of exempt accommodation that is provided by registered compared to non-registered providers, and is an appropriate balance being struck? The majority of exempt accommodation is predominately provided by registered providers. The levels differ between councils but between 72% and 85% is registered provision. From a local authority perspective there has been a growth in non-registered providers which has impacted on the subsidy paid to Councils. If this continues the subsidy loss is not financially sustainable and could impact other Council services.

• What is the proportion of exempt accommodation provided by commissioned compared to non-commissioned providers, and is an appropriate balance being struck? We do not have a means to gauge an accurate measurement in regard to this question.

• How does whether a provider is registered or non-registered, or commissioned or non-commissioned, impact the quality of provision? At District Council level we would not be aware of any differences in relation to the quality of provision.

• How should exempt accommodation be provided and what should the service cost? Exempt accommodation should continue to be provided by registered providers and charitable organisations. Councils should not be penalised financially because services are provided by a registered charity rather than by a registered provider. DWP should change subsidy arrangements so that councils recover full 100% subsidy for all exempt accommodation irrespective of landlord type.

• How should the regulatory oversight of exempt accommodation be organised? It would be very useful to have a limit placed on service charge increases similar to the annual adjustment rent formula. Currently where eligible charges are increased councils may only restrict based on a reasonableness test which is difficult to substantiate. Improved communications between commissioning authorities and relevant partner organisations with clear guidance and data sharing to enable more informed decision making.

• What should be the regulations governing exempt accommodation and how should those regulations be enforced? Exempt accommodation in general provides high quality accommodation. The most challenging area in ensuring that the provision of accommodation is fully funded while having a national approach to limit the level of service charges by an agreed formula each year.

• Is there sufficient publicly available information about exempt accommodation
• Information is generally available about what exempt is but there is not enough information publicised about the subsidy impact of non-registered provider.

January 2022