Written evidence submitted by Green Pastures CBS Ltd [EXA 045]
ORGANISATIONAL DETAILS
Green Pastures CBS Limited | Exempt Charity: XT27103 | Registered Number: 31116R | Registered in England and Wales | Registered with the Financial Conduct Authority | Registered Office: 9 Mornington Road, Southport, Merseyside, PR9 0TS | Green Pastures is the working title of Green Pastures CBS Limited and other associated companies.
BACKGROUND
On 7 December 2021 the Levelling Up, Housing and Communities (LUHC) Committee launched an inquiry into exempt accommodation which aims to establish a clearer picture of the amount and quality of provision of exempt accommodation. This includes understanding the strengths and weaknesses of current provision and looking for recommendations on the changes that might be needed to improve exempt accommodation. Green Pastures is responding by making its submission based on the inquiry’s terms of reference.
Commenced in 1999 we are writing in two capacities. Firstly, as the provider of 576 bedspaces where residents claim housing benefit under the regulations governing exempt accommodation. We call this “Green Pastures Direct”. Secondly, through the provision of advice, guidance and consultancy to local non-commissioned supported housing providers delivering 655 bedspaces. We call these “Green Pastures Partnerships”. We presently partner with 85 churches and charities across the UK. Our Partners also provide a further 1,411 bedspaces from other sources. Each partner is unique and provides care, support or supervision for between just 2 people and 500 people.
Our values, shared by our partners, are based on the foundational principles of our Christian faith: compassion, mercy, justice and authenticity. Our ministry is to end homelessness in the United Kingdom by inspiring and equipping the local church to provide accommodation and support for those most in need.
Green Pastures welcomes the committee’s review of the exempt accommodation sector in the hope that with regulation and inspection will come recognition of the high quality housing provision that is being delivered by the vast majority of providers in the non-commissioned sector.
2.1 What is the quality of exempt housing provision?
Despite the occasional headlines exposing an abuse of the housing benefit exempt accommodation regulations, in our experience the overwhelming evidence paints a rich picture of the non-commissioned exempt accommodation sector delivering very high quality housing provision.
This opinion is based on the regular scrutiny of both our own provision and that of our partners through rigorous control of property purchase, oversight of refurbishment and fitting out to a high standard and the regular monitoring of the care, support or supervision of residents through our dedicated quality control staff. This includes property inspections and the absolute insistence on safety certification, as well as training the members of Resident Support Teams. Regional Partnership managers regularly visit each supported housing project to review the quality of provision and create continuous improvement action plans. Some local authorities have stated our projects are exemplary models of supported housing.
This gives us the confidence to declare that the housing provision is of a very high standard.
In addition, there are informal relationships with other providers who share their own evidence of a high quality housing provision.
Specifically, we are pleased to report that, during our last Annual Partner Questionnaire, we surveyed 45 of our Partners and found that:
Of the 355 residents in their Green Pastures properties:
● 81 residents secured employment
● 59 residents commenced education or training programmes
And of the 45 Partners:
● 10 run Social Enterprise projects for their residents to gain skills and independence
● 26 encourage residents who have experienced personal development to mentor other residents
Local authorities have welcomed the role our partners play in achieving their strategic goals in response to national government initiatives to end homelessness.
We can provide video evidence that the properties are made into beautiful homes, equipped to a high specification and filled with appropriate soft furnishings that make residents feel valued and respected.
We can also provide video evidence of residents speaking openly about the high quality of the support they have received and how much they have valued their time in the supported housing project provided directly or through one of our partners.
2.2 Is the current model of exempt accommodation financially viable, and does it represent value for money?
The current model of funding exempt accommodation represents excellent value for money. This is because, as a property-related benefit, housing benefit only covers the property related housing management costs of a project. The provision of care, support or supervision of the residents is therefore provided by the charitable activity of the provider.
However, it is our opinion that using the, somewhat imprecise and ambiguous, housing benefit regulations to fund exempt accommodation is ultimately not sustainable. It is inefficient in the hours the Housing Benefit departments have to invest in interpreting and applying the complex set of guidance briefings.
An appropriately funded service needs to include the care, support or supervision provided to residents.
2.3 Are there significant geographical and regional differences in the provision and the problems of exempt accommodation?
We can only comment on our own provision which extends across the UK. Green Pastures maintains the same high standards across all of our projects.
2.4 What is the proportion of exempt accommodation that is provided by registered compared to non-registered providers, and is an appropriate balance being struck?
We do not have access to this information.
2.5 What is the proportion of exempt accommodation provided by commissioned compared to non-commissioned providers, and is an appropriate balance being struck?
We do not have access to this information. However, we and our partners are non-commissioned providers. We have noticed that attempts to evidence the environment which makes it possible for residents to claim housing benefit under the regulations for exempt accommodation, are being challenged by Housing Benefit departments in increasingly robust ways. Furthermore, we are seeing evidence across different local authorities of inconsistency in the interpretation and application of the Housing Benefit Regulations in respect of Exempt Accommodation.
We can evidence the significant value provided by small dedicated voluntary sector organisations delivering high quality exempt accommodation. These providers should not be “squeezed out”.
2.6. How does whether a provider is registered or non-registered, or commissioned or non-commissioned, impact the quality of provision?
In our experience there is substantial anecdotal evidence to suggest that some registered or commissioned service providers offer an impersonal and prescriptive service. Our providers are more passionate, nimble and flexible and can provide personalised tailored pathways to the residents. The difference is in the motivation of the resident support teams and the ability to provide innovative solutions, without being constrained by the procedures of some providers. Our teams are a mix of paid and volunteers.
2.7. How should exempt accommodation be provided and what should the service cost?
Exempt Accommodation should be provided by a mix of providers that includes the non-commissioned voluntary sector.
Central Government Funding, devolved to Local Authorities, should be made available to fund the property related costs and the support related costs. Cost should allow for fully funded rent schedules that include the provision of wrap around support.
Funding devolved to local authorities for the provision of "exempt accommodation" should be protected by a ring fence. If no such protection is put in place the likelihood is that funding could be used by local authorities to fund other services that it has a statutory duty to provide, which doesn't extend to providing exempt accommodation. When the now defunct Supporting People (SP)programme was first implemented the money devolved to local authorities was protected by a ring fence and the supported housing sector flourished for a while. However, once the ring fence was lifted, the money that had been allocated annually to local authorities for commissioning Supporting People services was subsumed into the local authorities’ annual settlement from central government. The absence of "protection" saw local authorities spend less on supported housing, as they had to prioritise spending on their statutory duties, whilst balancing budgets in the face of austerity measures imposed by central government.
There is evidence that the provision of quality supported housing saves the public purses significantly, in areas such as the NHS, the Criminal Justice System and the Social Care system.
Personalised support provided by supported housing providers can reduce the incidence of hospitalisation resulting from deteriorating mental health and substance misuse relapse, reduce the incidence of reoffending and prison committals and reduce the need for social care interventions.
It is therefore imperative in our opinion that monies devolved by central government to local authorities for providing Exempt Accommodation is protected. Failure to put in such protection risks a very real repeat of what happened to the SP Programme i.e. a greatly reduced number of Exempt Accommodation bedspaces.
2.8 How should the regulatory oversight of exempt accommodation be organised?
The local housing authority should be responsible for the regulation of exempt accommodation based on national guidance. Regulation needs to apply to more than just bricks and mortar, governance and finance and encompass the quality of care, support or supervision (CSS) provided as well as geo-spatial considerations such as the location and concentration of this type of accommodation. The licensing and inspection of Houses in Multiple Occupation (HMOs) should be expanded to include registered providers of such accommodation (because they are not subject to restrictions at present).
The local housing authority should be required to liaise with the relevant social services authority in relation to the regulation of CSS. This should be in a manner that would also engage a suitable regime for additional CSS needs assessments that go beyond housing related support that would normally be outside the typical exempt accommodation provider’s responsibility, expertise or competence.
2.9 What should be the regulations governing exempt accommodation and how should those regulations be enforced?
A new national regulatory framework should sever the funding link between Housing Benefit regulations and exempt accommodation. New regulations should create a bespoke set of guidelines, specifically related to the provision of exempt accommodation.
We do not feel that “enforced” is the most appropriate word to use in the context of delivering the new regulatory framework. The local authority should be encouraged to work ‘in partnership with’ and ‘guided by the regulatory framework’ to support providers who can demonstrate they can deliver a service that meets the requirements. This should always allow for new entrants into the sector. Quality should be enhanced by using a National Charter of Residents Rights and Exempt Accommodation Quality Standards – similar to an OfSted – evidence based assessments.
An independent appeals process would be needed as not all local authorities operate the same and our experience shows that sometimes local authorities act without compassion and potentially are discriminatory.
It is critical any change does not lead to only large organisations being able to provide Exempt Accommodation.
Any new regulatory framework should be as light and smart as possible. Under the Supporting People programme the Quality Assessment Framework (QAF) was the national regulatory framework given by central government to local authorities to implement. The QAF had many good qualities, not least the requirement for commissioned supported housing providers to evidence continual improvement in the support given to clients / service users and to engage them in this in a meaningful way.
The downside to the QAF was that it was a very bureaucratic, time consuming and costly system for local authorities and supported housing to administer. Our view is that there are lessons to be learned from this. In developing an Exempt Accommodation regulatory framework, we believe that central government should consult with Exempt Accommodation providers, residents and local authorities to ensure it is fit for purpose, easy to implement and not too administratively burdensome.
2.10 Is there sufficient publicly available information about exempt accommodation?
We would welcome greater transparency. This, in our opinion, would be served by a quality framework of nationally recognised standards. Each local authority would publish the findings of their annual reviews of providers. Providers could display the appropriate quality mark they have obtained on their website and all public documents.
Outside of providers of Exempt Accommodation and local authority Housing Benefit Officers, there seems to be little knowledge of what exempt accommodation does and why it exists. We have mentioned in answering 2.7 how exempt accommodation / supported housing can actually save the public purse by reducing demands on the NHS, the Criminal Justice System and Social Care System. By helping get residents back into paid employment it also makes a positive contribution to the Department of Work & Pensions. We would like to see this highlighted, believing that better understanding of exempt accommodation would facilitate greater partnership working between exempt accommodation providers and the aforementioned statutory bodies and result in more and better quality outcomes for all concerned - not least the residents of exempt accommodation.
January 2022