Written evidence submitted by Golden Lane Housing [EXA 016]

Summary

Golden Lane Housing is a national specialist learning disability housing association set up in 1998 which provides homes to over 2,400 people with a learning disability and autistic people.

• We believe that the majority of supported housing provided by housing associations, including those classified as exempt accommodation under housing benefit regulation are good quality. The issues highlighted in the non-commissioned schemes across some UK cities do not represent most of the provision.
• There is clear evidence of the value for money specialised supported housing for people with a learning disability and autism provides. A report by Mencap in 2018 sets out the clear benefit of this provision and the increasing future demand for accommodation.
• Supported housing for people with a learning disability or autistic people is in great demand and increasing all the time.  The exempt accommodation regulations are critical to supporting the current and future supply, and any specific problems or abuses in the Housing Benefit exempt sector clearly need to be addressed.  
• Our experience is the level of due diligence across local authorities which administer housing benefit across England and Wales varies as does the knowledge and experience of local authorities in this area of housing benefit regulation. 
• The biggest impact on rent levels for our sector is the cost of capital and the specialist nature of the accommodation provided. Factors that influence the costs included location, scale, size and specific adaptations. It is crucial that Housing Benefit system be adequately flexible enough to take into account of these differenced in scheme costs.
• We believe that all future supported accommodation should be commissioned and supported by local or health authorities.
• We believe that there are strong regulatory arrangements in place for Registered Providers (in terms of both quality and value for money), and the upcoming changes to the regulatory framework around consumer standards (overseen by the Regulator of Social Housing) will support in future regulation.
• Housing Benefit is not the appropriate route for quality control in supported housing. This is not what the regulations were designed to do and it would be unreasonable to expect benefit managers to monitor the quality and value for money of supported housing. There should not be different quality oversight purely on the basis on the level of housing benefit that is received by the tenant.

• We are members of the Learning Disability and Autism Housing Network and the coalition set out our calls for action which highlight many of these points in our Charter launched in 2021 at the National Housing Federation Housing Summit.

Golden Lane Housing

Golden Lane Housing works with people with a learning disability and autistic people to provide supported housing around which they can build their lives. We were established as an independent registered charity by Mencap in 1998 to help tackle the immense challenges that people with a learning disability face in finding a home.

Since our inception we have invested £122.8 million transforming the lives of over 2,400 people with a wide range of needs in more than 1,200 properties across England, Wales and Northern Ireland. Each year we house over 200 people and continually find innovate ways to provide suitable housing solutions in this ever-changing society.

We work in partnership local authorities and health authorities along with more than 150 support providers to ensure people have access to the support they need to live independently in their home and community.

We provide housing for people who have commissioned support and a high level of support.  Many of our tenants have moved from hospital, institutional settings and families who are unable to provide long term care. We provide specialist landlord services to meet the needs of our tenants. We have our own in-house repairs team, Resolve Solutions providing a personalised service to tenants across England.

At Golden Lane Housing the average rent per unit (including eligible service charge) for our Housing Benefit exempt accommodation is £224.67 (31/03/21), which we believe is comparable or in some cases below the average for the learning disability and autism supported housing sector (Funding supported housing for all, Mencap, 2018).

Golden Lane Housing is a registered housing association and is subject to the Regulator of Social Housing’s regulatory framework, including the Rent Standard. Most of our supported housing rents are excluded from the requirement in the Rent Standard, including the obligation to charge ordinary social housing rents. Within our supported living accommodation, the grounds for such a Rent Standard exception are that the lettings are defined as Specialised Supported Housing (SSH).

These lettings also fall within the Housing Benefit exempt category which is separate requirement to meet. Most of our tenants claim Housing Benefit under the exempt accommodation rules. Therefore, we are an exempt accommodation provider. However, we strongly believe that we are not like the providers about which the committee has significant concern.

What is the quality of exempt housing provision?

We believe that the majority of supported housing provided by housing associations, including those classified as exempt accommodation under housing benefit regulation are good quality. The issues highlighted in the non-commissioned schemes across some UK cities do not represent most of the provision. 100% of our existing schemes meet the Decent Home Standard. All properties are inspected by our own staff including housing and property staff at least annually. We have a highly effective day to day repairs in-house service services, national contracts for compliance, and a 10 year asset management strategy. We have invested heavily in the fire safety of our stock and made financial provision in our business plan for the decarbonisation of our stock.

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

There is clear evidence of the value for money specialised supported housing for people with a learning disability and autism provides. A report by Mencap in 2018 sets out the clear benefit of this provision and the increasing future demand for accommodation. Mencap reported that on average supported living costs £191 per week less than residential care and £1,931 less per week than a hospital inpatient setting.

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

We aware of issues in some UK cities but our experience is regional differences are limited and are largely created by differences in local commissioning strategies. 

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

We do not have access to any data on this subject. However, our subjective view is that a large proportion of supported living accommodation for people with a learning disability or autistic people is owned or managed by Registered Providers.

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

All of our supported housing provision is supported by commissioners which is required to be excluded by Rent Standard provisions to charge social rents.

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

The majority of supported living accommodation for people with a learning disability is provided by Registered Providers, but we are not aware of any data that provides quality comparisons.

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

Supported housing for people with a learning disability or autistic people is in great demand and increasing all the time.  The exempt accommodation regulations are critical to supporting the current and future supply, and any specific problems or abuses in the Housing Benefit exempt sector clearly need to be addressed.  But it is important that this does not destabilise the essential work being carried out by the majority of quality providers.

Our experience is the level of due diligence across local authorities which administer housing benefit across England and Wales varies as does the knowledge and experience of local authorities in this area of housing benefit regulation.

The biggest impact on rent levels for our sector is the cost of capital and the specialist nature of the accommodation provided. Factors that influence the costs included location, scale, size and specific adaptations. Over the last twenty years SSH has been the main way supported living for people with a learning disability and autistic people has been provided by the Registered Provider sector. One of the main reasons has been the grant system has been unable to meet the needs of this client group. Those that have been funded by grant have tended to be for people with lower support needs.  The current grant system has not been flexible and responsive enough to meet the commissioners’ demands in relation to design, location and pace of provision. It is crucial that Housing Benefit system be adequately flexible enough to take into account of these differenced in scheme costs.

How should the regulatory oversight of exempt accommodation be organised? What should be the regulations governing exempt accommodation and how should those regulations be enforced?

We believe that all future supported accommodation should be commissioned and supported by local or health authorities.  We believe that there are strong regulatory arrangements in place for Registered Providers (in terms of both quality and value for money), and the upcoming changes to the regulatory framework around consumer standards (overseen by the Regulator of Social Housing) will support in future regulation. Housing Benefit is not the appropriate route for quality control in supported housing. This is not what the regulations were designed to do and it would be unreasonable to expect benefit managers to monitor the quality and value for money of supported housing. There should not be different quality oversight purely on the basis on the level of housing benefit that is received by the tenant. We would support additional proportionate measures and accreditation for non-registered housing associations with local authority commissioners, recognising the important role charities play in the sector. 

The regulations governing exempt accommodation should continue to be overseen and administered by local authorities, but in a more consistent way developing expertise and clear guidance.  Housing benefit administering authorities should develop stronger links with the commissioning bodies of services to support strategic priorities for the delivering of supported housing.

Is there sufficient publicly available information about exempt accommodation?

There is limited publicly available information and there are opportunities through the new £300m pot identified in the recent Social Care White Paper to support a better understanding by commissioner. We are concerned about the unintended consequences of additional oversight or changes purely because of the failures of one part of the sector. Many of the issues caused in the sector are a result of lack of scrutiny and due diligence in some authorities, poor strategic planning, lack of sufficient capital grant funding for supported housing and uncertainty around the future funding of supported housing though welfare benefits / housing benefit. Many longstanding housing associations have stopped providing supported housing, including exempt accommodation, because of these issues. We are members of the Learning Disability and Autism Housing Network and the coalition set out our calls for action which highlight many of these points in our Charter launched in 2021 at the National Housing Federation Housing Summit.

January 2022