Written evidence submitted by Lotus Sanctuary CIC [EXA 039]
 

Introduction

My name is Gurpaal Singh Judge, and I am the CEO of Lotus Sanctuary CIC, a housing provider that manages 2000 units of accommodation of which 1000 is exempt accommodation. We provide accommodation for domestic violence and abuse victims, rough sleepers, and prison leavers. We are set up as a community interest company and not regulated by the regulator of social housing. We formed Lotus in 2018 seeking to house rough sleeping females in the Wolverhampton area of the West Midlands. We found that the demand for our accommodation far outstripped supply, and as such we have seen a rapid expansion in the work we do, alongside the growth of the different groups of people we serve. We are seeking to provide evidence to the committee to stress the importance of the work we do and highlight the demand for our services.

What is the quality of exempt housing provision?

The quality of exempt housing varies from provider to provider. Our portfolio of properties exceeds the decent homes standards and are all fully compliant. All our exempt properties are fully furnished, with residents receiving lounge furniture, a bed, wardrobe, chest of drawers, appliances, bedding, and cutlery. All our accommodation for mothers with children is fully self-contained, without any shared facilities. We pride ourselves on the quality of our housing, always keeping in mind that our residents are human and deserve to be given the best chance of overcoming the problems that lead them to needing accommodation. Further to this, we provide our residents with ongoing support, with a view of empowering them to overcome the issues that have led them to homelessness.

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

Our median rent charges are £242 per person per week, a yearly charge of £12,584. This rent enables us to support residents for up to 3 hours per week, cover lease costs of the property, cover property maintenance and compliance, and support our head office functions. In comparison, the charity Crisis estimates the cost of a single rough sleeper to be £20,128 per annum*... a net saving of £7544 per annum.

The same applies to domestic violence victims, with the following extract from a January 2019 Home Office report** “To estimate the unit cost for an average domestic abuse victim, the total cost estimates have been divided by the total estimated number of domestic abuse victims (1,946,000 in the year ending 31 March 2017 (Office for National Statistics, 2017a)). The estimated cost for a single victim of domestic abuse is £34,015. While this represents an average, there are a range of different types of violent and sexual offenses that victims of domestic abuse can experience. Most extreme is the cost of domestic homicide, which has an estimated unit cost of £2.2 million arising from the cost of harms, health services, and lost output.” With our housing intervention and support, we garner a net saving of £21,431.

Again, with prison leavers, we find similar statistics of huge costs being incurred because homeless prison leavers turn to reoffending to survive, with Crisis stating that reoffending costs the economy £13.5billion per year. Further stating that having stable accommodation upon release from prison cuts reoffending by 20%. ***

These statistics prove the financial viability of exempt accommodation for the client groups that we serve. Its further worth noting that there is a lack of suitable alternative accommodation available, bringing into question what would happen to rough sleepers, domestic violence victims, and prison leavers without the provision of exempt accommodation. 

*Cost of homelessness | Crisis UK | Together we will end homelessness

**The economic and social costs of domestic abuse (publishing.service.gov.uk)

***Prison leavers | Crisis UK | Together we will end homelessness

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

We have exempt housing in all the regions of England. Demand for our services is equal overall but differs regionally dependent on client groups. In the Midlands, we have heavy demand for mothers with children escaping domestic violence. In London, we see a large demand for single male rough sleepers. Similarly in the Northwest and Northeast, we see heavy demand for prison leavers who would alternatively be homeless upon release from prison. In terms of problems relating to exempt accommodation, regionally we have seen newer entrants to the sector, who lack the experience that larger providers have, acquiring units of accommodation in areas where housing is generally cheaper (predominantly Birmingham, Rochdale, Preston, and the Northeast). This has caused issues with local authorities, who in certain areas lack a comprehensive knowledge of exempt accommodation. Local authorities have subsequently taken a negative view on exempt accommodation, in some areas outright claiming that exempt providers are providing accommodation for profit-making purposes. Systematically, we as a provider of high-quality housing have been accused of being a “pop up landlord” by a few local authorities, even after showcasing the work we do and proving our status as a not-for-profit company.

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 are a non-registered provider that currently offers 1000 bed spaces/units of exempt accommodation. We don’t have evidence as to the exact balance of non-registered vs registered providers. We feel strongly that non-registered providers should make up a large proportion of the exempt market space given that many of the non-registered providers, ourselves included, we’re created for the specific purpose of helping vulnerable people and offering practical solutions to issues like homelessness and domestic violence. Whereas our registered colleagues are social housing providers ahead of exempt housing providers.   

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

All our current provision is non-commissioned. We feel strongly that the commissioning of support services to complement exempt accommodation is needed for the client groups that we serve. There is a lack of resources at the local authority level in commissioning bespoke homeless/rough sleeping and domestic violence accommodation-based support. 

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

Registered providers face more regulation in ensuring the quality of the housing compared to non-registered providers. The provision of the support on the other hand is the same for both registered and non-registered bodies, given that local authorities regulate residents’ support and administer housing benefit claims. Again, the commissioning of services relates directly to the care and support residents receive, and the difference in housing provision or the quality of the homes themselves are not impacted by commissioning.

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

The current model of exempt accommodation works in that it provides homes and support to the most vulnerable members of society that is cost-effective. The commissioning of support packages to supplement the housing provision is needed, with current costs via housing benefit only being high enough to cover minimum support and ensuring properties are decently maintained.  

How should the regulatory oversight of exempt accommodation be organised?

The regulatory oversight should be administered at the local authority level within the benefits team, with each team having exempt accommodation officers who are knowledgeable and trained around the legislation. Currently the process of applying for “exempt status” is different from council to council, with some having intensive application forms while others just requesting a rent breakdown. The new model will see exempt officers being responsible for the handling of a uniform online application form that is the same for every local authority, with the officer further doing an inspection of the property at the application stage. The form will ask for details around the properties, clients that will be housed, proof of the housing provider being non-profit, etc. Following a successful application, the exempt officers will also oversee the handling of residents’ housing benefit applications. Local authorities currently administer and regulate exempt accommodation within general housing benefit teams, with many team leaders and managers not fully understanding the exempt legislation which causes delays in processing applications and claims, which in turn can lead to cash flow issues for the providers.

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

The regulations that are currently in force, namely that the provider is a non-profit organisation that offers the residents care, support or supervision are sufficient to ensure that providers are not profit-motivated. Further to this, an annual audit of the property condition should be undertaken by members of the local authorities housing benefit team to ensure it is meeting decent homes standards and the properties are fully compliant. If the provider does not meet the standards or the properties are uncompliant, local authorities should enforce this via tight deadlines to rectify issues, followed by providers being stripped of exempt status if they do not make improvements. The current measures within the local authority of reviewing support plans are sufficient to prove a level of ongoing support is being provided to residents.

Is there sufficient publicly available information about exempt accommodation?

Some councils publish information about exempt accommodation, which differs from council to council, with some providing information on their websites as to what exempt accommodation is and others showing nothing. Further, recent negative press coverage about exempt accommodation has casted a shadow over the work that the good providers are doing in this desperately needed service. For safeguarding reasons, it would be prudent to avoid disclosing locations of exempt properties, given that this will cause a major risk to vulnerable residents.

January 2022