Written evidence submitted by St Petrocs [EXA 025]

St Petrocs background

St Petrocs is a local, independent charity working with individuals who are experiencing homelessness in Cornwall.  We have a 35-year history and have developed our services over this time.  The annualised turnover for the 2020/21 financial year was £3.6 million.

St Petrocs is registered as a Company, limited by guarantee (No. 12320784). It is registered as a charity with The Charity Commission (No. 1187077). St Petrocs does not deliver any commissioned services.  It is not a Registered Provider.

St Petrocs provides services in support of people who are homeless or at risk of becoming homeless, including outreach, resettlement, emergency accommodation, supported accommodation (145 bedspaces) and floating support once people move on from our accommodation into independent living.  We provide access to advice, support, and medical services at our two resource centres and have an in-house counselling service called Freshfield.  We also have an employment and training programme.  Our goal is to provide the support required for our clients to find a permanent route out of homelessness.

Whilst the services we provide do not have any eligibility criteria, we tend to support those for whom there is no statutory care or support obligation.

St Petrocs supported accommodation qualifies as ‘Exempt Accommodation’.  As such, the housing management costs associated with this residential service are eligible for Housing Benefit, where the resident is entitled to claim it. The care, support or supervision provided to residents of the service (which is required to qualify as ‘Exempt Accommodation’) is funded through charitable means, either from grant funders or from donations received by the charity.

St Petrocs is submitting evidence because we believe ‘Exempt Accommodation’ plays a crucial role in ending homelessness in Cornwall.  We welcome the inquiry into the standard of service provision in this area.

Further information is available at our website www.stpetrocs.org.uk.

What is the quality of exempt housing provision?

St Petrocs strives to deliver a good quality of service, tailored to the individual needs of our residents.  Whilst there is no recognised standard to measure against, the below response sets out our approach to quality in respect of supported accommodation provision.

St Petrocs has 145 bedspaces across 21 properties throughout Cornwall.  Our accommodation ranges from self-contained single bedroom units to houses in multiple occupation with the number sharing these houses ranging from two to ten people. The allocation of people to our accommodation is based around the needs of the residents and, where capacity allows, we consider which type of accommodation would suit the individual best.

St Petrocs owns the freehold to eight houses with the remainder being leased from various landlords including the local authority, the Church of England, a local care home provider and other private landlords.

We seek to keep the properties in good repair and have a programme of planned maintenance.  Routine inspections of properties are undertaken to comply with health and safety regulations and fire safety legislation.  Checks include electrical and gas safety inspections, legionella assessments, fire risk assessments, environmental assessments and asbestos surveys.  Where required, we obtain the necessary House in Multiple Occupation licence from the local authority.

Residents are provided care, support or supervision by a team of 15 Supported Accommodation Officers which is a ratio of one officer to every ten residents.  The Supported Accommodation Officers are based in the property they are assigned to and are available to residents at various times during the day depending on the immediate needs of the residents. This includes early mornings or late evenings if required but would usually be between the hours of 9:00am to 5:00pm.  We operate our residential support services seven-days-a-week.  We have some properties which are too small to accommodate a permanent staff presence.  In these locations, a Supported Accommodation Officer visits the property two to three time per week.  Outside of normal working hours, St Petrocs operates an ‘on-call’ service for residents which is manned by two staff members and a Service Manager on a rotational basis. The on-call service is available 365 days a year. 

The Supported Accommodation Officers are supported by two Service Managers, one Rent Officer, one Associate Director and one Director of Residential Services.  The Supported Accommodation Officers duties are split between housing management tasks and care, support or supervision activities.  Where necessary, further care, support or supervision is provided to residents by our counselling service, by volunteers or by engagement with our employment and training programme.

St Petrocs seeks external accreditation where possible for both operational and support functions.  St Petrocs currently holds the following accreditations:

• Investors in People: Gold Award
• ISO 9001:2015 Quality management systems
• ISO 14001:2015 Environmental management systems
• The Contractors Health and Safety Assessment Scheme accreditation certificate
• Registered with the Fundraising Regulator
• Cyber Essentials: Certificate of Assurance

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

Whilst the cost of supported accommodation could be considered relatively high, it is lower than that which would result if a person was not in supported accommodation, as set out in the figures presented below.  The aim of supported accommodation in our service is to give people the time and support required for them to progress into independent living following a period of homelessness.  There is no statutory funding available to our client group for the support we provide.  This work is charitable funded.

Most people housed within our ‘Exempt Accommodation’ are not in employment.  We see engagement with training and employment opportunities as a progression out of homelessness for good.  We encourage our residents to engage with training and employment when they are ready to do so.  Supporting people into employment through our residential services means that, as they move on into independent living, they will begin to contribute towards society through employment taxes.

Our residents stay with us for an average of 38 weeks.  Whilst supported accommodation could be seen as a relatively expensive housing solution if taken in isolation in the short term, it provides a route for people to move into lower cost, sustainable housing thereafter.  Over the longer term, this undoubtedly provides good value for money especially when the impact of people obtaining employment is considered.

The average cost of St Petrocs supported accommodation is c. £25,000 per year, per resident; c.£19,000 of this is funded via Housing Benefit.

This cost can be set in the context of the estimated cost of homelessness in England.  Figures from Crisis, the national charity for people experiencing homelessness, in 2015[1] and 2016[2] suggest that the cost of interventions required for a single person sleeping rough in England is £20,128 per year, and that the estimated average cost to the public purse for people experiencing homelessness for more than 90 days is £34,518 per year.  These indicative costs of homelessness developed by Crisis do not include any costs of accommodation.

Figures from Cornwall Council suggest that the average housing cost of temporary accommodation (B&B) for a single person in Cornwall is between £6,240 - £8,060 per year. However, the support needs of a person suitable for our supported accommodation is higher than those who are placed in temporary accommodation with no support.

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

St Petrocs response is based solely on experience of operating in Cornwall since inception in 1986.  We are not able to offer any response more widely on this question.

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

It is our view that the quality of provision does not depend on whether a provider is registered or non-registered, or commissioned or non-commissioned.  Whilst being a Registered Provider or a provider of commissioned services results in a measure of oversight either from the Regulator of Social Housing or the commissioning body, it does not guarantee a high service quality.

Similarly, there are examples of organisations who deliver excellent quality services who are neither Registered Providers nor commissioned services.

In the context of supported accommodation for people experiencing homelessness for whom there is no statutory duty owed, care, support or supervision is delivered by the provider without the need for commissioning as there is no statutory service being commissioned.  If it became a requirement for ‘Exempt Accommodation’ providers to be commissioned, it would preclude providers such as St Petrocs from delivering supported accommodation.  In this situation, the service would not be economically viable under the current Housing Benefit regulations.  This would result in a reduction in the capacity of supported accommodation.

St Petrocs is a charity which relies upon fundraising and public donations to finance the support work across both residential and non-residential services.  For charities such as St Petrocs, it is important to consider the potential implication of becoming a Registered Provider on the ability to raise charitable funds for our services which extend beyond supported accommodation provision.  If it became a requirement for ‘Exempt Accommodation’ providers to become Registered Providers, it would potentially limit the ability of organisations such as St Petrocs from obtaining funding for other charitable work.

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

We do not believe that there is a requirement to further prescribe the nature of organisations that qualify as providing ‘Exempt Accommodation’. Paragraph 4(10) of Schedule 3 to the Housing Benefit and Council Tax Benefit (Consequential Provisions) Regulations 2006 states that for a Housing Benefit claimant to be classed as living in ‘Exempt Accommodation’:

Either:

• The accommodation has been funded in the past by a resettlement grant under section 30 of the Jobseekers Act 1995 from the Department of Social Security (now the Department for Work and Pensions (DWP)). This could apply to some hostels and similar kinds of accommodation.

Or

• The claimant must be living in a property that is provided by:

o a housing association,

o a registered charity,

o a non-profit making voluntary organisation, or

o in England only, a non-metropolitan county council

and

• ‘…that body or a person acting on its behalf also provides the claimant with care, support or

supervision….’

Including a further requirement to be a Registered Provider or a commissioned service provider would not necessarily affect the quality of the service provision.  However, it would be beneficial to develop some standards around the provision of care, support or supervision to ensure that providers of ‘Exempt Accommodation’ delivered effective services.

How should the regulatory oversight of exempt accommodation be organised?

If regulatory oversight was brought in, in respect of service standards, it is our view that this should be done on a national level to avoid regional or local variations in how the regulatory framework was applied.  To avoid duplication, the regulatory body could be established in an existing regulator such as the Regulator of Social Housing.

We believe there should be separation between any oversight of service standards and the body that decides upon Housing Benefit claims so that local authority financial or budgetary considerations could not influence the rating of service quality in the context of whether a particular Housing Benefit claim could be treated as being for ‘Exempt Accommodation’ or not.

There are existing regulations which govern the eligibility of costs of ‘Exempt Accommodation’ for Housing Benefit which are applied by local authorities.

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

St Petrocs would welcome the introduction of national standards governing the quality of care, support or supervision provided in ‘Exempt Accommodation’.  There is currently no legal definition of what constitutes care, support or supervision. The introduction of standards in this area would provide clarity for both providers, commissioners and Housing Benefit offices at local authorities.

In respect of the standards of accommodation, there are existing standards that are applicable for Houses in Multiple Occupation.  Currently, if there are five or more unrelated people living in a house in multiple occupation, the landlord is required to obtain a licence from the local authority.    If the threshold of five people was reduced for ‘Exempt Accommodation’ providers, it would lead to more landlords being measured against this standard.

Alternatively, the Decent Home Standard (which is currently subject to its own review) could be brought in specifically in respect of ‘Exempt Accommodation’.

January 2022