Written evidence submitted by Stepping Stone Projects [EXA 024]
About Stepping Stone Projects
Formed in Rochdale in 1984, Stepping Stone Projects (SSP) is an independent, registered charity which aims to prevent and combat homelessness. SSP is not currently a registered housing provider.
SSP prevents homelessness by providing quality, affordable homes and independent living support to many of the most vulnerable people in Greater Manchester and Lancashire at risk of homelessness. Our Board of Trustees are volunteers. Any surpluses are re-invested into services in pursuit of our mission to prevent homelessness.
SSP currently provides over 550 homes with both commissioned and non-commissioned support services to 12 local authorities across 25 boroughs in the North-West. This benefits c720 vulnerable people at any point in time and a total of c1200 homeless and vulnerable people annually. The number of people SSP accommodates and supports is growing all the time as the demand for our homes and services continues to increase.
SSP currently provides c385 homes (70%) that are commissioned, the rents are not HB eligible and therefore don’t rely on Exempt Accommodation rules (eg care leavers, NRPF and UASC). SSP provides c165 homes (c30%) that are commissioned and non-commissioned which do rely on Exempt Accommodation rents and service charges though.
The homes and support services SSP provide benefits a range of vulnerable people at risk of homelessness including:
- rough sleepers,
- statutory & non-statutory single homeless people,
- care leavers,
- vulnerable young people at risk who would likely otherwise be in local authority care,
- Unaccompanied Asylum-Seeking Children,
- ex-offenders & prison leavers,
- adults with complex needs (eg mental health, substance abuse and offending issues),
- adults with low level mental health issues,
- Afghan & other refugees or asylum seekers,
- those with No recourse to Public Funds
- survivors of modern-day slavery
We also provide preventative floating support services to households at risk of homelessness.
SSP accommodation is a mix of intensively managed and supported grouped schemes and less intensively managed dispersed accommodation with floating support. Most are fully self-contained homes, albeit we have about 40 units of HMO accommodation with some shared facilities.
SSP use a mix of SSP owned, Registered Provider (RP) and privately rented homes. Some SSP owned and privately rented homes are leased to RPs and these are then sub-leased to SSP via a management agreement. This is to ensure property and housing management standards are of the highest quality and costs are minimised. However, we still have some homes where these arrangements with RPs are not in place. This is usually because they are commissioned services where a local RP is not required, there is no local RP prepared to enter into these arrangements or where accommodation and support is required so urgently or on such a short-term contract that it has not been possible to put such arrangements into place.
1. What is the quality of exempt housing provision?
SSP can only provide evidence of our own accommodation. The properties SSP use are of a very high standard. SSP don’t use properties that don’t meet either SSP or RP standards, especially on safety issues (eg HHSRS, gas, electrical, water) and basic amenities (eg central heating, security). Our commissioned services have high property standards that our commissioners set, monitor and enforce.
In many cases, both our commissioned and non-commissioned services are either owned or leased by an RP (including with private rented sector landlords) and SSP then rent or lease from them. In these circumstances the RP regularly inspect the properties to ensure SSP are meeting all the property and housing management standards of the Regulator of Social Housing.
Where an RP doesn’t own or lease the property, SSP ensure the properties meet the same standards. Standards are also monitored and enforced by the local authority concerned through a combination of their building control, homeless, housing strategy, Housing Benefit, private sector and environmental enforcement teams.
All SSP properties are fully furnished because our customers usually don’t have access to furniture, cooking utensils and crockery.
SSP is aware that not all providers of exempt accommodation meet the kinds of standards we strive for and deliver. SSP have seen some indirect evidence of this when customers have moved from an unsuitable private sector provider to our accommodation and the local authority and/or customers have provided us with their reasons and concerns.
We also have some limited direct evidence of this when we have acquired some previously private sector exempt accommodation which was of poor quality. SSP have then invested heavily into the refurbishment of the accommodation to bring it up to high standards. We recently purchased a 15 room HMO and invested a further c£150k to improve it to the standards we insist on, with new bathrooms, kitchens, flooring, lighting, security, CCTV, fire safety works, decorating etc completed. The works were completed by a local RP to ensure they meet the highest (regulatory) standards as well.
We have also leased some similar recently developed properties from other private sector landlords which have been completed to very high standards. In one instance the landlord was prepared to invest a further £40k to ensure the property met a local RP’s, as well as regulatory, very high standards.
2. Is the current model of exempt accommodation financially viable, and does it represent value for money?
Since 2010 Local Authorities have had to make many cost savings and reduced the amount of accommodation and support services they offer to many vulnerable people. Many vulnerable people no longer meet social services’ ever increasing thresholds for statutory services.
A lot of Councils are struggling with the increasing demand and level of need, and in a large number of cases simply cannot afford to commission and pay for the number of supported homes they need to safely accommodate these vulnerable people. Their complex needs mean they need additional housing management and support services to develop the skills needed to succeed as tenants and to sustain independent living. A few need such support long term on an on-going basis.
Exempt accommodation is often the only means by which the Councils and the charities and other providers on which they rely, can provide this accommodation and support which many of the most vulnerable and desperate need. Their complex needs, lifestyles and previous histories of debt, tenancy and ASB problems, eviction/abandonment and tenancy failures mean that for many social and private landlords simply will not or cannot house them. For these people with support needs, exempt accommodation is the only option they have, at least initially until they have either stabilised their lives and/or they can be provided with wrap around support.
SSP seek to deliver all our services at the lowest possible cost to customers, commissioners and local authorities. Where possible, we try to engage local RPs to either provide their own accommodation at social rents or to become the lessee of private rented accommodation to ensure high property and housing management standards.
With the additional levels of scrutiny and challenge SSP Exempt Accommodation, services and charges are subject to from local housing benefit teams and other local authority departments, we believe our services do represent good value for money. The accommodation and support are generally provided at lower average unit costs than our commissioned services. This usually reflects the lower level of housing management and support service offered and/or needed.
The exempt accommodation model is still financially viable for SSP despite the margins being very low and so the financial risks are high on any one project. This risk is mitigated as we provide a large number of homes and services across a wide range of boroughs thereby spreading the risks.
Currently all those local authorities utilising exempt accommodation insist on detailed break-downs of rents, proposed services and costs, service charges (including the quality of the services being provided). All regularly monitor, review and check these services and costs.
However, SSP are aware of instances where some landlords have seemingly exploited Exempt Accommodation to provide poor quality homes and services at inflated prices and so make super normal profits.
It is for others to judge whether SSP and overall Exempt accommodation and services offer value for money and whether the total cost of this type of accommodation is financially viable. However, unless there is a significant amount of immediately available new affordable supported accommodation provided through registered housing associations, local authorities or through commissioning at high cost, Exempt Accommodation (or something similar) is needed. There will be a lot of very vulnerable people at risk of or homeless if they are denied this accommodation and/or support. As has been evidenced elsewhere the upstream costs to the public purse of this would be far greater in terms of the increased costs of temporary accommodation, adult social care services, physical and mental health treatment, substance abuse therapies. Police and other blue light services, court and prison costs etc.
3. Are there significant geographical and regional differences in the provision and the problems of exempt accommodation?
Undoubtedly. SSP’s experience is that some local authorities try to resist the development and provision of Exempt Accommodation regardless of the level of need in their borough, often to the detriment of vulnerable and homeless people. There are local examples of where this type of approach has led to vulnerable people being accommodated in unsuitable and more expensive temporary accommodation, sometimes out of borough. Other local authorities currently have little or no supported accommodation available to them for certain types of customers’ needs (e.g. vulnerable single adults with complex needs and/or mental health issues) and they rely on other authorities or property in other boroughs to meet these needs.
We are also aware of many other local authorities who manage Exempt Accommodation very well. They have in place robust systems and procedures to check and agree eligible rents, services, charges and costs in advance of new developments taking place and they continually monitor them and the standards delivered thereafter.
Through the media SSP have become aware of some local authorities where such robust management and scrutiny of Exempt Accommodation has not seemingly been delivered and some abuses seem to have taken place (most notably the well reported cases in Birmingham). However, SSP haven’t experienced any local authorities in the North-West where we are aware this is the case.
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?
As a non-registered provider of housing, SSP works very closely with registered housing providers to allocate or lease as much of our accommodation as possible. RP’s ensure and deliver regularity standards to our homes and housing management services.
SSP currently use c200 RP homes charged at social rent levels (ie c40% of our total provision) provided by 12 registered providers. We also have another c50 private rented homes that RP’s lease on our behalf (a further c10%).
The remaining 50% of SSP homes do not currently have registered provider landlords or involvement. These are primarily in our commissioned services either providing:
- very short-term emergency accommodation (eg A Bed Every Night services for Rough Sleepers, homeless singles) or
- short to medium term accommodation where the beneficiaries are not able to claim HB (eg care leavers, young people, UASC, refugees and people with no recourse to public funds) and so an RP landlord is not required or does not bring the same benefits as the commissioners determine the property and furnishing standards which are often higher than those of any regulator.
Less than 20 SSP homes (<5%) are currently exempt accommodation without an RP landlord. SSP are now working to either replace these homes or to lease them to an RP.
5. What is the proportion of exempt accommodation provided by commissioned compared to non-commissioned providers, and is an appropriate balance being struck?
SSP have 6 services providing c65 homes that are commissioned that rely on exempt accommodation. c55 of these homes are RP owned or leased.
SSP have 7 services and c100 homes that are non-commissioned that rely on exempt accommodation. c90 of these homes are RP owned or leased.
6. How does whether a provider is registered or non-registered, or commissioned or non-commissioned, impact the quality of provision?
SSP do not believe that being a registered housing provider is necessary to ensure the provision of quality homes and services. SSP aim to deliver the highest quality homes and services possible by meeting our own high property, housing management and support service standards . We have also introduced robust compliance and assurance mechanisms and invested in additional management resources to ensure we deliver to these standards and report back to them to Board and our commissioners.
However by working in close partnership with Government, commissioners, councils, registered providers and private landlords and funders (as described above) we can ensure that we also meet other regulatory standards (eg Regulator of Social Housing) and the specific needs, wants and standards of our commissioners and partners.
SSP do believe that national minimum standards for the quality of exempt and non- exempt supported accommodation should be introduced, along with minimum standards of housing management and support. These standards will then need monitoring and enforcing by a regulatory authority with formal notices and proportionate penalties applied for non-compliance. This will then ensure high quality services are provided by all providers to agreed minimum national standards.
7. How should exempt accommodation be provided and what should the service cost?
See other answers for responses.
8. How should the regulatory oversight of exempt accommodation be organised?
There seems to be 3 main choices:
Establish a new Supported or Exempt Accommodation regulator. The costs of this will be relatively high and will take some time to set up and get started. Providers will probably need to pay relatively high fees to cover the costs of this – of course this will be reflected in higher rents
Add the role to an existing regulator – almost certainly the regulator of social housing. This would probably be less expensive (lower overheads and shared costs with RP’s) and quicker to set up. Fees would be payable by providers as above as passed onto through rents – albeit likely lower than above.
Or take a different approach by ensuring local authorities, who are currently responsible for this sector but without all the necessary commissioning, planning/development and enforcement powers, are better equipped to monitor, manage and enforce new services and standards by:
- Developing and agreeing national minimum property and service standards for exempt and supported accommodation providers and giving Council’s the power to enforce these standards locally
- Ensuring Council’s are the only ones that can commission (including any at nil cost) new and existing exempt accommodation provision in their local areas. They can then agree the extent and type of exempt accommodation and services to be developed and provided in their locality based on their assessment of local housing needs (they already do some of this through their housing, homelessness and adult social care commissioning services)
- Giving Council the power of veto to any new applications for exempt accommodation developments and services proposed in their borough’s where there is no evidenced and recognised local housing need, the proposed development is not suitable as a building, site or location or where the service is deemed inappropriate for the needs of the intended client group or if the rents and costs are deemed excessive and/or are unjustified.
- Giving Councils the formal requirement and power to agree in advance of development the exempt accommodation rents, additional services and charges to be set based on the cost of these services and for them to continually monitor and scrutinise the properties and services to ensure they meet the standards wanted and promised.
- Giving local councils the necessary and proportionate formal notice and enforcement powers to ensure national and local property and service standards are met at all times. This should include the ultimate sanction to shut down the accommodation and services for serious and/or continual breaches (especially concerning H&S issues) and /or where there are failures to take remedial action where serious detriment notices are issued.
9. What should be the regulations governing exempt accommodation and how should those regulations be enforced?
- Agreed national minimum standards for homes and properties, housing management, tenancy and support services.
- All exempt accommodation provision is commissioned (whether at cost or nil cost to the local authority) and approved by local authorities based on their assessment of needs and demand in their borough
- Local authorities agree the nature of the accommodation, the services and service levels to be provided, the eligibility and reasonableness of costs prior to any new developments and services being agreed.
- Local authorities monitor, inspect, manage and enforce all the standards and receive appropriate performance management and compliance information from providers in a timely fashion as determined by either standards or the individual local authority
- Local authorities continue to deliver existing and other regulatory duties and functions on the exempt accommodation providers such as planning, building control, routine H&S compliance, insurance checks, financial viability of the provider, housing management and support service compliance etc
10. Is there sufficient publicly available information about exempt accommodation?
No. The “market” seems to work largely through referrals from other organisations or word of mouth between vulnerable customers and their friends and family. There is little awareness, scrutiny or accountability to or by the general public and what there is tends to be when things may go significantly wrong or becomes a major problem that the media highlight. There are no statutory or regulatory rights or agreed procedures for customers or families to complain or appeal decisions other than through other property, tenancy or consumer legislation breaches. There is little or no transparency across the sector.
January 2022