Written evidence submitted by South Yorkshire Housing Association [EXA 042]

SYHA was set up nearly 50 years ago following Shelter’s establishment, mid growing concern about homelessness and housing conditions of vulnerable people. We remain true to this mission today. We provide supported accommodation services for over 1500 people in the Sheffield City Region. SYHA is the largest provider of care and support in Yorkshire and the Humber, and the second largest in the North of England. Care, support and employment services represents 50% of our turnover.

The following section answer the TOR question:

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

• We believe that the majority of supported housing provided by Registered Providers (RP’s) is good quality, including those classified as exempt accommodation under housing benefit regulation.
• We believe that there are strong regulatory arrangements in place for Registered Providers. The changes to the regulatory framework around consumer standards (overseen by ROSH) will support future regulation.
• Where we have Managing Agents, a management agreement is signed and subject to SYHA scrutiny via our Quality Assurance team. SYHA retain responsibility for maintenance, stock investment, and servicing.
• Many of the issues caused in the sector are a result of poor strategic planning, lack of sufficient capital and the removal of revenue grant for supported housing.
• There is less regulation of for-Profit providers of exempt accommodation working under lease arrangements. We believe it is more important that the provider is registered and regulated with the Regulator of Social Housing.
• Our exempt status has driven innovative models of support (see below) which are making savings to the public purse.

The following section answers the TOR questions:

What is the quality of exempt housing provision? & is the current model of exempt accommodation financially viable?

Our intention isn’t to feel protectionist, but we do feel that RP’s are trusted to drive quality in exempt accommodation. Most of the additional costs relates to service charges. We have strong governance arrangements in place and make sure essential building related charges are fair and proportionate and provide quality by:

• Following the NHF “Service Charges – A Guide for Housing Associations”

• Using specialist external brokers to lower costs (i.e., energy suppliers for communal utility charges)
• Receiving annual quotes from contractors to benchmark VFM and quality
• Conducting competitive tenders for maintenance contracts based on VFM and quality
• Having robust Internal Audits carried out by external partners to assess quality of accommodation and provide Board assurance
• Scrutiny from our Extra Care customers, who challenge our variable service charge costs and hold us to account.

Our regulatory framework supports all of the above. Conversely, the profit motive means that the risk of inflated rents by claiming exempt status is greater in the private sector. Local Authorities, though Housing Benefit sections, have the means to identify outliers at a local level and challenge costs. We know from our own experience that this is happening, and we have been challenged over costs.

How should the regulatory oversight of exempt accommodation be organised?

Standards of decency in the social housing sector are far better than in the Private Rented Sector.  South Yorkshire Housing Association is a strong supporter of the PlaceShapers’ ethos.  One of the principles of PlaceShapers’ associations is to build close, constructive relationships with local authority partners.  Our experience in South Yorkshire is that over-spread landlords who may manage homes in the Sheffield City Region do not have a strong local presence – particularly at a senior level.  Their Boards and executive teams are inevitably remote.  

We suggest that a requirement to work effectively locally with local councils and Mayoral Combined Authorities (where applicable) should be built into the Regulatory Code, and that the Regulator of Social Housing should monitor this. Under previous regulatory frameworks, the regulators routinely contacted the local authorities in the areas associations operated in and invited their views on the quality of this relationship. Restoring this accountability would be a progressive step for supported exempt accommodation.

Finally, the National Statement of Expectations (NSE) for supported housing already provides a comprehensive framework for quality. Local Authorities teams should measure exempt accommodation against the standards.

The following section provides practical examples to answer the TOR questions:

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

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

Without exempt accommodation status we would not be able to provide the following services:

Extra Care – Non-commissioned

We support over 300 tenants though the provision of Extra Care within the Sheffield City Region. After the removal of the supporting people ring fence, commissioned support was withdrawn. Our exempt status allows us to apply an Intensive Housing Management (IHM) charge so that our staff can remain on site to provide essential safety and security actions. Staff provided a lifeline in Covid-19. They also provide assurance against the regulatory standards and the NSOE. By only commissioned services receiving exempt status, we would be left with the very difficult decision to remove staff from site or require tenants to cover any top up payment. The second scenario will disproportionately affect our poorest pensioners. In terms of savings to the system, we believe there would be at least an additional 100 people requiring more 24-hour expensive residential care.

White Willows

Out of hospital service – Non-commissioned

Our Living Well project in Sheffield brings people with acute mental health needs back to their hometown of Sheffield from out of area. This is fully funded via an IHM charge and is estimated to have made saving to the Health and Social care system of £50K per customer, per year, since the project started in 2015.

LivingWell

Homelessness and Housing First – Part- commissioned

We provide over 120 homeless units of accommodation in the Sheffield City Region. Without the exempt status and access to higher rents for essential services (including security and higher wear and tear costs) we face the real possibility of closing these services down. This is contradictory to what the government are aiming to achieve via the Homeless Reduction Act and the Housing First model.

Housing First Report

January 2022