Written evidence submitted by the Local Government Association [EXA 020]
1.1. The Local Government Association (LGA) is the national voice of local government. We are a politically led, cross party membership organisation, representing councils from England and Wales.
1.2. Our role is to support, promote and improve local government, and raise national awareness of the work of councils. Our ultimate ambition is to support councils to deliver local solutions to national problems.
Summary:
2.1 People living in exempt accommodation deserve to live in decent homes and to receive good quality, personalised support that meets their needs. Councils are very concerned that a minority of providers operating across the country fall short in providing this for people in vulnerable circumstances. This includes people who are homeless and need additional mental health or substance misuse support, people fleeing domestic abuse, prison leavers, care leavers and people leaving national asylum seeker services.
2.2 Increased demand for exempt accommodation – combined with the funding model for supported housing, outdated Housing Benefit regulations, a lack of local oversight and planning powers and a weak national regulatory framework – have created the conditions for a minority of unscrupulous non-commissioned providers to take advantage of the higher rents that can be charged for exempt accommodation to maximise financial gain for private investors.
2.3 This has a significant and detrimental impact on the lives of the people who live in poor-quality housing without the right level of support, and the wider community, as well as a cost to the public purse. Currently councils have very limited levers to control exempt accommodation quality and over-supply in their communities.
2.4 Given the impact of poor-quality exempt accommodation on individuals and communities across the country, there is an urgent need for central government action. The LGA wants to work with Department for Levelling Up, Housing and Communities (DLUHC), Department for Work and Pensions (DWP), the Department of Health and Social Care (DHSC), the National Housing Federation and other partners, to ensure that exempt accommodation is consistently good quality, provides the right support and represents value for money.
2.5 We need a thorough review of supported housing funding, including support costs when a person does not meet the threshold for social care support and addressing the subsidy gap that councils with housing responsibilities face in relation to non-registered supported housing, to determine how to ensure sufficient and sustainable funding in response to local need. This will give certainty to reputable providers and ensure commissioners have the necessary transparency to ensure quality standards and value for money.
2.6 Building on the work of the Government’s supported housing national statement of expectations and five council supported housing pilots, councils want greater flexibilities, oversight and enforcement powers to ensure provision is in line with local need and take effective action against poor providers whilst maintaining a proportionate approach to good providers. Housing Benefit regulations, planning rules and the national regulatory framework for exempt accommodation need to be urgently reviewed and strengthened so that loopholes are closed. Councils and the Social Housing Regulator (SHR) must have sufficient resources, oversight and enforcement powers to clampdown on unscrupulous providers.
2.7 In particular, a requirement of exempt accommodation status must be council approval so that locally assessed quality of accommodation and support is a condition of operation through a fully funded local licensing or accreditation scheme linked to quality standards. We would welcome working with Government to develop a costed model for strengthened local oversight and enforcement, building on the work of the pilots, and the long-term savings it could achieve for councils and Government. It must be recognised that the pilot councils received extra government funding to develop different approaches and, in some instances, further funding is needed to continue this work.
In the longer-run strengthened local oversight and enforcement will save money for the public purse by eradicating unreasonably high rents, ensuring people’s support needs are met and mitigating the impacts of poor provision on communities and the local housing market. The definition of care, support or supervision in the current Housing Benefit regulations must also be strengthened, so that there is greater clarity about the level of care and support that must be provided and against which councils can assess compliance.
2.8 A scaled-up focus on tackling the minority of exempt accommodation providers who take advantage of the current system should also encourage some of the more mainstream Registered Providers back into the market and ensure future provision is needs driven and in line with local supported housing plans.
2.9 Exempt accommodation cannot be viewed in isolation from the general needs housing market (especially the shortage of affordable rental homes) and planning, welfare and social care reforms. The Social Housing White Paper’s commitment to strengthen consumer regulation and the role of the Regulator of Social Housing, and the Adult Social Care White Paper’s welcome funding and focus on councils’ strategic leadership role in relation to supported housing offer important opportunities to start to address councils’ concerns.
Questions:
3.1 It should be noted that exempt accommodation ‘status’ is an entirely legitimate way in which mainstream supported housing providers ensure that their residents continue to receive Housing Benefit to meet their housing costs (rather than Universal Credit) and that they can recover their legitimate costs of providing good quality long term supported housing. These are usually higher than for general needs social housing. For example, because of higher maintenance costs, repairs and renewals, security and health and safety measures.
3.2 Over the last few years there have been increasing concerns amongst councils, many supported housing providers and the Government, about the use of exempt accommodation by some segments of the supported housing sector and the impact of this on both the quality of accommodation and the quality of support services provided to people in vulnerable circumstances. Most of these concerns relate to short-term exempt accommodation for working age adults that has not been directly commissioned by the council and therefore the council has few levers to address quality concerns, including support.
3.3. Birmingham City Council has identified a trend for landlords of other types of housing, including houses in multiple occupation (HMOs) and family homes, to change their accommodation status to become supported housing. This is typically housing provider-led development of supported housing rather than council commissioned or approved supported housing. In some of these circumstances accommodation that is not of a suitable quality, for example in relation to space standards, is being used to house people who have care and support needs, with significant consequences for people’s wellbeing. This trend is in part being driven by landlords who do not provide supported housing being advised that providing supported housing can attract higher rents with exempt accommodation and more attractive financial returns. Registered providers of exempt accommodation are exempt from HMO licensing rules, and family housing that is changed to exempt status is also exempt from some council powers, including Article 4 Directions.
3.4 There is also a concern that the provision of support in some non-commissioned exempt accommodation when people do meet social care thresholds is not necessarily reflective of the needs of people and, rather, it is simply a means of complying with the exempt accommodation regulations (i.e. that support is provided by the landlord or on the landlord’s behalf to tenants). People living in exempt accommodation have additional care and support needs, alongside accommodation needs. The provision of good quality and personalised support is essential to supporting positive outcomes for people living in exempt accommodation and enabling them to move into longer-term suitable accommodation. Care and support services will vary according to people’s needs, but can include mental health support and substance misuse support Unscrupulous landlords who receive high exempt accommodation rents are also incentivised to keep people in exempt accommodation rather than supporting them to become more independent and secure longer-term good quality accommodation.
3.5 Where supported housing has not been commissioned or approved and where people may need support but may not be eligible for council funded social care, then there are no contractual mechanisms for councils to quality assure and monitor care and support services in this type of supported housing. In some areas councils have become aware of issues with the quality of support services in non-commissioned supported housing primarily through safeguarding alerts. Councils have limited roles to check and intervene where there are quality concerns about the capability and skills of the organisations that are providing support. These difficulties can be compounded when people are offered non-commissioned exempt accommodation in another council area and often have no or limited connections to the ‘host’ council. This is a key concern for councils and must be looked at as part of strengthening local oversight of exempt accommodation.
3.6 In addition to the detrimental impact of quality concerns on the health and wellbeing outcomes of people who live in exempt accommodation, there are also knock-on effects for communities. If people are not receiving the support they need to address often quite complex needs, then they can sometimes engage in behaviours that disrupt or harm the local community, such as anti-social behaviour. Prospect Housing has highlighted that the concentration of vulnerable residents with different support needs in poorly managed properties with inadequate support can place a “disproportionate and unsustainable demand on public services.” Birmingham City Council’s April 2021 report to Cabinet on Exempt Accommodation highlights serious concerns about the potential of criminal activity within exempt accommodation housing “which in turn exacerbates the vulnerability of tenants.”
4.1 In the last financial year, it is estimated that councils spent £1 billion on exempt accommodation, a figure that has increased over the last three years. Anecdotally, most of this funding enables people in vulnerable circumstances to live in good quality accommodation and receive support and care that meets their needs. However, the quality concerns highlighted in response to the previous question suggest that in some places exempt accommodation does not represent value for money because their support needs are not being met and that this is a growing problem.
4.2 The ability for providers to charge higher rents for exempt accommodation is important. The costs of managing shared supported housing units are higher than general needs social housing and such schemes would not be financially viable if the same Housing Benefit and welfare rules applied to exempt accommodation as general needs social housing. Most Housing Benefit claims from exempt accommodation providers are legitimate, but councils with responsibility for housing do not always have a clear picture of the costs to enable them to scrutinise value for money. There is also evidence that rising rents have in part been driven by a minority of landlords who are seeking to exploit the outdated Housing Benefit regulations for financial gain.
4.3 Rents in supported housing should reflect the actual costs of providing that accommodation. These costs will usually be higher than for general needs housing, however they should be reasonable and justifiable. While councils can use powers under the Housing Benefit regulations to restrict unreasonable supported exempt accommodation rent increases in limited circumstances, the significant practical difficulties with doing so means that this rarely happens. As we go on to explain, addressing the root causes of councils’ value for money concerns will require a fully funded local oversight regime, updated Housing Benefit and planning regulations that currently limit councils’ ability to act against poor providers and ensure provision is in line with local need, and more effective national regulation.
4.4 There are also concerns about the growth in private sector investors attracted to develop supported housing that has exempt accommodation status, primarily as a high return investment model, typically leasing this accommodation to non-stock owning smaller Registered Providers to manage on their behalf. This issue has grown significantly in scale over the last few years and resulted in a small but growing number of Registered Providers being issued with regulatory notices and downgrades by the Regulator of Social Housing for both governance and financial viability. There is nothing inherently concerning about the lease-based model and private investment has an important role to play in funding supported housing alongside the public sector, but current gaps in the Housing Benefit regulations mean that there are large sums of money passing between some not-for-profit registered housing providers and for-profit landlords. This is something which the National Housing Federation has raised concerns about.
4.5 For some councils responsible for housing with a proportionately high number of non-registered exempt accommodation providers, their main concern is the Housing Benefit subsidy gap they face. Councils receive 100 per cent subsidy in relation to social housing landlords, but only 60 per cent in relation to charitable landlords and 0 per cent if the person is not classed as vulnerable. This shortfall is a further budget pressure on already stretched council budgets, especially smaller district councils. East Staffordshire Borough Council is among the councils that have raised concerns about the subsidy gap. Across England, in 2020-21 the Housing Benefit Subsidy loss faced by councils ranged from £0 to £3.7 million. For 23 councils, the subsidy loss was over £1 million. Giving councils with responsibility for housing the powers they need to address value for money concerns will save public money and start to close the subsidy gap. However, it should be noted that most exempt accommodation Housing Benefit claims from charitable non-registered landlords will be legitimate and therefore the Government must act to close the Housing Benefit subsidy gap councils face.
4.6 The issue of funding care and support costs when a person does not meet the threshold for social care support also needs to be addressed. Whilst there have been numerous government reviews of supported housing funding, most recently in 2018 when it was decided that housing costs for all types of supported housing would continue to be funded by Housing Benefit, these have not fully addressed the issue of funding care and support costs. There can be a lack of transparency about accommodation and eligible service costs (funded by Housing Benefit) and support costs (which cannot be funded by Housing Benefit). Crisis has highlighted that some providers may have reclassified some support costs as housing-related costs so that they can be covered by Housing Benefit, which has pushed up rents.
4.7 Alongside strengthened definitions of care, support and supervision within the current Housing Benefit regulations, there needs to be sufficient revenue funding in the system so that providers have certainty of funding for support costs and commissioners have the necessary transparency to ensure quality standards and value for money. Prospect Housing has highlighted how the support provided in its accommodation was “far in excess of what could be reasonably described as enhanced housing management, making it ineligible for Housing Benefit”. As support costs cannot be met from Housing Benefit, the cost was met by levying a service charge on residents which they met from their weekly Universal Credit entitlement with a significant impact on personal finances.
5.1 The five government supported housing pilot areas (Birmingham, Blackburn, Bristol and Hull) experience particular challenges with exempt accommodation, but it is a growing nationwide issue and most major cities have seen rapid growth in non-commissioned supported provision, particularly for homeless people or people with alcohol or substance misuse issues and it is of significant concern that some people’s housing and support needs are not being met. Further work is also needed to understand the issues faced by district councils. DWP information obtained through a Crisis Freedom of Information request suggest that in May 2021 there were in the region of 153,000 exempt tenancies in Great Britain, a 62% increase from the 95,000 cases recorded in May 2016.
5.2 The impacts of converting family homes to exempt accommodation will be greater in housing markets that have an undersupply of larger family-sized accommodation, but a high demand for this accommodation.
5.3 Therefore, we need a locally-led fully funded oversight and enforcement regime for exempt accommodation within a strengthened national regulatory framework, so that councils’ responses can be tailored to the challenges they face and the contexts of local housing markets and demand. Stronger local oversight will also help to address challenges that can arise when a person moves into exempt accommodation in a different council area, sometimes without any contact with the host council. Further use of out of area protocols should also be considered to address this key concern for councils.
6.1 We are not aware of nationwide data about the proportion of exempt accommodation that is provided by registered or non-registered providers. Analysis by Birmingham City Council suggests that registered providers make up about 90 per cent of the local exempt accommodation market, but the picture in other parts of the country will be different and reflect the local housing market. For example, in Blackpool, the proportion of registered providers is about 30 per cent and growing.
6.2 Similarly, we are not aware of nationwide data about the proportion of exempt accommodation provided by commissioned compared to non-commissioned providers. Anecdotal evidence suggests that most concerns about exempt accommodation relate to a minority of non-commissioned providers which in turn suggests the balance is not right and mainstream commissioned providers need to be incentivised back into the supported housing market. However, in some places the quality of provision varies across both types of exempt accommodation. A fully funded and robust local governance and monitoring regime would improve all types of exempt accommodation.
7.1 Most exempt accommodation providers are reputable organisations that put the needs of their residents first and are as concerned as councils are about the minority of providers who exploit the system and damage the sector’s reputation.
7.3 The National Housing Federation has recently changed its membership policy for new members so that it can block any applications for membership from providers looking to enter the sector for financial gain. In addressing exempt accommodation problems in some places, we must not destabilise existing and much-needed good provision. This highlights the importance of working in partnership with organisations like the National Housing Federation and organisations representing charitable providers, including faith groups, on shared solutions.
7.4. Most exempt accommodation is provided by registered providers. Registered providers are exempt from HMO licensing rules and management, which as Birmingham City Council has emphasised, makes this a more attractive option for unscrupulous providers, and can make it more difficult for councils to ensure that accommodation is safe given registered providers are not subject to HMO rules.
7.5 Crisis has also highlighted that if registered providers are judged to be providing ‘non-social housing’, they are not subject to the Regulator of Social Housing’s regulation (although in this instance they would be subject to HMO licensing).These regulatory gaps have caused problems in particular neighbourhoods with clusters of non-commissioned registered provision. There is also an issue with registered providers who can own ‘non-social housing’. In this case while they are registered, the Regulator has fewer powers over those particular properties.
7.6 Some exempt accommodation is commissioned or approved by councils or other public sector organisations. Quality is monitored and managed through contractual arrangements It should be noted that in two-tier areas the district and county council will have different roles and responsibilities. It is possible for non-commissioned providers to work proactively and positively with councils to ensure that good quality accommodation and support is provided. However, feedback we have received from councils suggests that most of their concerns about the quality and value for money of exempt accommodation stem from non-commissioned lease-based provision.
7.7 People can be placed in non-commissioned exempt accommodation through a variety of referral routes from multiple agencies, including self-referrals. There is no requirement to notify the council in advance, so the council is unable to check whether the accommodation and support are suitable. Councils do scrutinise Housing Benefit claims for exempt accommodation, but they do not have effective powers to challenge unreasonably high rent claims and few levers to challenge concerns about care and support by an uncooperative non-commissioned provider unless there are safeguarding issues. Further consideration is needed about an appropriate mechanism to raise and address concerns about care and support and the workforce implications of this.
8.1 Exempt accommodation provision should be driven by local need. Most councils’ concerns about non-commissioned exempt accommodation would be addressed by establishing council control over all referrals into exempt accommodation supported housing in their area, for example through a single referral ‘hub’ involving county councils and district councils working closely together in two-tier areas. This would enable councils to ensure that new provision is established to meet local need and would deal with issues such as preventing ‘self-referrals’ or providers giving a home to people from other council areas without sharing vital information. This is likely to require additional resources for councils and an enforcement mechanism being created linked to strengthened Housing Benefit regulations and planning rules. Housing Benefit regulations should be amended so that exempt accommodation must be commissioned or approved by the council. Alongside this, an accreditation or licensing scheme linked to a quality framework should be introduced. Any licensing or accreditation scheme should consider the capability and size of the provider and their portfolio so that it is not overly restrictive or costly to deliver whilst maintaining good quality provision.
8.2 It is crucial to incentivise ‘mainstream’ housing associations to both re-enter the supported housing market and to deliver additional supported housing where they are already active in developing such housing. In particular, the availability of suitable properties, certainty about the stability of funding for the supported housing sector (Housing Benefit and revenue funding for support costs), the potential for higher levels of capital grant rate funding for supported housing from Homes England and potential for changes to the Rent Standard to provide supported housing landlords more flexibility in relation to (justifiable) rent levels in supported housing. As poor providers may exit the market, councils will need a decommissioning strategy in line with homelessness prevention duties.
8.3 There is a need for further research into what exempt accommodation should cost to provide, but this must recognise that costs will vary according to the level of support that is required, the local housing market and the financial model for individual schemes. Anecdotal evidence suggests in some places exempt accommodation is costing too much because of artificially high rents, especially through the lease-based model for registered providers when it has been established with the explicit aim of maximising investor profit. Councils and other public sector bodies also face increased expenditure from addressing the consequences of poor quality exempt accommodation and support, both for individuals and communities. We have also highlighted the need for sufficient and sustainable revenue funding, clearer definitions and greater transparency about housing and support costs to help councils assure themselves that it represents value for money.
8.4 Moving to a strengthened local oversight and enforcement regime with councils acting as a central hub for all exempt accommodation and proactively addressing quality and value for money concerns, will require additional resources for councils to set up and maintain different approaches and ensure sufficient capacity. Similarly, a strengthened role for the RSH and addressing regulatory gaps for Community Interest Groups (see page 11), will have resource implications. However, in the longer-term this investment should result in savings to the public purse from a reduction in unjustifiably high Housing Benefit claims and fewer instances of service breakdown. We would welcome working with Government to develop a costed model for strengthened local oversight and enforcement, building on the work of the pilots, and the long-term savings it could achieve for councils and Government. It must be recognised that the pilot councils received extra government funding to develop different approaches and, in some instances, further funding is needed to continue this work.
9.1 An exempt accommodation provider can set up and largely operate outside of the regulatory framework with neither councils, the CQC (unless social care is commissioned) nor the Regulator of Social Housing (RSH) having sufficient oversight powers. This regulatory gap is a further incentive for the minority of providers who use exempt accommodation status to maximise income while delivering poor quality services for their residents.
9.2 Most providers will be registered with the RSH and subject to the associated regulatory framework. However, the RSH does not have the powers or remit to proactively regulate consumer standards and can only use its enforcement powers where there is, or is risk of, serious detriment. Its current remit is largely limited to matters of financial viability and governance with a greater focus on private providers which own 1,000 units or more.
9.3 Over recent months the long lease-based model for supported housing has come under scrutiny by the RSH, particularly the governance and financial arrangements of some RPs that lease all or most of their housing stock from other organisations, typically private investors. The RSH has published a number of regulatory judgements and notices where it has identified concerns about the governance or financial viability of these providers.
9.4 Through the Social Housing White Paper, the Government has committed to “Transform the consumer regulation role of the Regulator of Social Housing so it proactively monitors and drives landlords’ compliance with improved consumer standards.” Given that many of the issues with current exempt accommodation arise from consumer issues such as the standard of the accommodation and support provided and the impact of poorly managed exempt accommodation on communities, we urge the Government to strengthen the Regulator’s role in relation to existing exempt accommodation as part of reforming the Regulator’s powers through the Social Housing White Paper.
9.5 We are encouraged that the RSH has strengthened the due diligence scrutiny by the that takes place when a landlord applies to become an RP, specifically when they intend to provide supported housing. We would like the RSH to formally seek the views and experiences of councils. It could also include a formal mechanism for intelligence sharing between RSH officials and councils in relation to supported housing providers that are a cause for concern to either party (for example in relation to geographic areas of operation of a current landlord or where a landlord proposes to provide supported housing).
9.6 Registered providers can also be subject to regulation by a number of other bodies, including the Charity Commission (if they are registered charities and not exempt from regulation by this body); the Financial Conduct Authority and the Office of the Regulator of Community Interest Companies (CIC) if they have been established as CICs. Prospect Housing has highlighted how some lease based exempt accommodation providers are forming a CIC – removing residents from social housing and the protections offered by the sector. Close working between RSH and Office of the Regulator of Community Interest Companies is required to discuss applications to set up CICs for lease based exempt accommodation purposes. We would also support a tight definition of “not-for-profit” in the Housing Benefit regulations.
9.7 There needs to be further consideration of registered exempt accommodation not judged to be social housing with units let at market rents, because this is beyond the remit of the RSH. A registered provider only needs to have one unit of social housing and can then provide many units of non-social housing which is excluded from the rent standard.
9.8 Councils with housing responsibilities have an important oversight role when checking that Housing Benefit claims comply with the requirements set out in legislation. In the case of non-commissioned provision, this can be the only opportunity to scrutinise and identify concerns with the limitations we have already highlighted. As we have said elsewhere in this submission, councils need greater flexibilities, oversight and enforcement powers to ensure provision is in line with local need and to act against the minority of non-commissioned providers who do not provide good quality exempt accommodation, alongside a stronger RSH and updated Housing Benefit and planning regulations that close the current loopholes.
10.1 The current Housing Benefit regulations are out of date and have loopholes in them that are being exploited by the minority of exempt accommodation providers motivated by profit maximisation. Given the impact of poor providers on people and communities, these gaps must be urgently closed through secondary legislation.
10.2 The definition of exempt accommodation in the Housing Benefit regulations should be amended via Statutory Instrument so that a criterion for exempt status, and therefore receiving higher Housing Benefit, is that the application for exempt accommodation must be approved in some way by the council with close working between district and county councils in two-tier areas. Alongside this, a licensing, inspection or accreditation scheme should be introduced that is linked to quality standards and reflective of individual support needs. Exempt accommodation status would therefore be subject to council approval and conditional on good quality and meeting the individual’s support needs. This would provide reassurance for local communities and councils would have greater powers to manage new provision. DWP is in the process of finalising strengthened ‘housing benefit guidance for supported housing’ and has consulted with councils in its preparation. While we welcome strengthened guidance, councils are clear that guidance remains open to interpretation, and changes to the regulations and definitions are needed to address many of the key issues related to quality and costs.
10.3 Strengthening local oversight of value and quality will ensure that provision meets local need, improve services for people and improve value for money. There is a precedent for the principle of council approval of supported housing, Specialised Supported Housing (SSH) must be commissioned by the council or NHS to be classified as SSH. It is defined within the Government’s Policy statement on rents for social housing (2020) as supported housing that is “provided by a private registered provider under an agreement or arrangement with a local authority or a health service (within the meaning of the National Health Service Act 2006)”. As mentioned above, we recognise that the requirement for council commissioning or approval of exempt accommodation would need to be reflected in Housing Benefit regulations, and for there to be a suite of tools that will strengthen confidence in assessments.
10.4 Council assessment of applications from providers for exempt accommodation status is in line with councils’ existing roles and there are already people in housing teams who carry out quality checks. In two-tier areas, this will involve close working with adult social services. There will of course be some resource implications for councils, which Government will need to fully fund, but these could be offset by the savings to the public purse from clamping down on unjustifiably high rents.
10.5 A further difficulty is that there is no clear statutory definition of what “care, support and supervision” means in the Housing Benefit regulations. Case law set out in Bristol City Council v AW [2009] UKUT 109 (AAC) indicates that “a satisfactory test for determining whether support of more than a minimal amount is provided is to ask whether the support provided was likely to make a real difference to the Claimant’s ability to live in the Property”. The definition “more than a minimal amount” introduces a high degree of ambiguity around what a resident can expect in terms of the amount of support that is provided and how it is to be funded. A council cannot refuse to pay Housing Benefit if the evidence provided showed that “more than minimal” support was being provided, even if that support did not meet a person’s needs. The treatment of support within the Housing Benefit regulations needs to be thoroughly reviewed and definitions clarified, alongside sufficiency of revenue funding where a person does not meet the minimum threshold to receive social care support.
10.6 Finally, the definition of an HMO in schedule 14 of the Housing Act 2004 should be amended so that a non-profit registered provider of social housing is classed as an HMO and therefore subject to HMO licensing requirements. This will give councils greater powers to enforce accommodation quality standards.
11.1 The Government’s supported housing pilots have undertaken work to further empower residents and improve their understanding, for example through the Charter of Rights that was developed in Birmingham by Spring Housing and co-designed with residents. We encourage the Government to share this learning with the wider sector and also to recognise that much of the pilots’ work was only possible due to the extra funding that the pilot councils received. strengthened local oversight and more effective regulation of exempt accommodation would result in a better understanding, including for people moving into and living in exempt accommodation to understand their rights, how to raise concerns, and receive appropriate and timely information to make informed decisions about their housing. Without proper support, it can be difficult for people to leave exempt accommodation and find a longer-term home that is right for them.
This submission reflects internal policy development work commissioned from the Housing LIN (author, Ian Copeman).
January 2022