Written evidence submitted by West Midlands Combined Authority Faith Strategic Partnership Group [EXA 049]

Inquiry 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.

About the West Midlands Combined Authority Faith Strategic Partnership Group (WMCA FSPG)

Key members of West Midlands faith and community groups come together to help improve the lives of all residents in the Region.  Organised by the West Midlands Combined Authority (WMCA) the new Faith Strategic Partnership Group consists of 26 representatives from different religions and ethnicities.

Andy Street, the Mayor of the West Midlands, said: “The work of local faith groups is highly valued, especially the strong contribution they have made during the pandemic. They have helped spread the word to their communities about everything from safety messages to support available to businesses.

“A very strong field of applicants was received for a small number of places so I am sure this new group will make a significant contribution to the recovery of the West Midlands.”

Members of the group identified priority areas and strategies to tackle these from a faith perspective. These areas include homelessness, education, employment, poverty, community relations and leadership. The group’s members are expected to network within and beyond their communities and collaborate with other faith groups.

The group’s priority is to support the WMCA’s Covid-19 response, especially around the issue of health inequalities highlighted by the recent Regional Health Impact of Covid report.

The group’s first meeting was held on Tuesday 15 December 2020 and the was attended by the Mayor Andy Street and Cllr Brigid Jones, WMCA portfolio lead for inclusive communities and deputy leader of Birmingham City Council, who welcomed the group.

Cllr Jones said: “The new Faith Strategic Partnership Group represents a balance of religious affinities, gender, age and geography to create the right mix of members which is truly representative of the faiths in our region.

“I look forward to hearing from them on some of the key issues facing our communities in the West Midlands.”

Just over three years ago a faith steering group was created to work with the Mayor’s office and the WMCA. Over the past months the group has supported WMCA’s faith briefings which bring together faith groups by holding weekly online meetings chaired by the Mayor. The virtual round tables provide faith leaders and representatives with updates on Covid-19 from local authorities and public health experts, and on funding and support available and the opportunity to hold to account each week’s panel about issues that directly affect their communities.

The members were chosen on the basis that they have the strategic capacity and foresight to ensure faith makes a strong contribution to the work of the region. We were particularly keen to include younger faith representatives so we can contribute to the development of the faith leaders and advocates of the future. We are passionate about calling upon all the amazing individuals who expressed an interest to join and involve them in future discussion. We are also indebted to the outgoing Faith Steering Group who have to pave the way for this next phase. Following the outbreak of the pandemic vital voluntary services were set up by the wide range of faiths in the West Midlands to help anyone affected by the current crisis, regardless of belief. Their good work has been supported by West Midlands Combined Authority (WMCA) and highlighted on the WMCA website.

What is the quality of exempt housing provision?

Varies from very good to very poor. Depends on the provider, the local authority and a number of factors.

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

With proper oversight and regulation, the exempt housing sector could be vastly improved and represent better value for money. This is not the only consideration however since the service is necessary for many reasons and therefore the cost needs to be covered. The issue is about balancing the cost control and the quality of the provision at the same time and not having these things pitted against each other.

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

Yes, very clearly. The application process in some local authorities is taken extremely seriously and it is very difficult to secure exempt accommodation status on application to the council. This is certainly true in local areas of the LAs of Wolverhampton and Sandwell for example. Other LAs are more lax about the criteria and the applications of the legal requirements for benefitting from exempt accommodation status such as in Birmingham and it is our understanding that the areas where it is given out all too readily without proper scrutiny are the ones that are having issues and problems. We are concerned about this inconsistency and the negative impact on vulnerable people, local residents and the wider impact. The are areas in the WM that seem saturated and have a high concentration of EA – this will ultimately have a knock-on effect to many other local dynamics.

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

Technical question requiring access to data, we simply do not have access to – there are concerned groups trying to work in the sector struggling to make any inroads trying to get reliable valid. This further compounds the perception and transparency around EA and the negative image / impact.

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

Technical question requiring access to data, we simply do not have access to.

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

Whether an organisation is registered or not does not seem to have any impact on the quality of the provision. The main impact it carries is the ability of the LA to reclaim full cost recovery from central government or only a proportion of the full cost which in and of itself causes issues throughout the process.

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

The current system could be made work with proper regulation, scrutiny, transparency and oversight. It is intended to be cost based. If the cost of providing the service is simply a recovery of actual costs which is how it is intended and this were to be properly scrutinised and overseen then again, the current system could be made to work.

How should the regulatory oversight of exempt accommodation be organised?

A distinction needs to be made between regulation and oversight. Regulation should apply to how an organisation is structured, managed and financed. Oversight, in contrast, should apply to what it does, in this case the delivery of supported housing. It is proposed that regulation could be done within the context of the Local Authority whereby organisations applying for exempt accommodation status have to demonstrate minimum standards in governance, financial management, operational competence, diversity and inclusion. This could be done in a similar manner to the way it used to be applied under the former Supporting People Initiative. It is our understanding that this is already done by some LAs such as Wolverhampton and Sandwell (from feedback received) where the application process for obtaining exempt status contains a significant element of regulation.

The oversight related to the quality should not be within the remit of the LA commissioning the services. If the element of cost control which is the main priority of the LA is also overseen by the LA in terms of quality control then there is a risk of a significant conflict of interest. Oversight needs to be about Value Generation and independent from the cost considerations. Quality should not have to be compromised in order to achieve cost control for Local Authorities. Specific provision should be made for independent quality control and that information should be fed back to the LA as commissioner in order to input into the decision-making process.

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

Answer to the previous question covers this question as well.

Is there sufficient publicly available information about exempt accommodation?

No - there is very little information in the public domain about this issue and how we are seeking to serve and protect some of the more vulnerable members of our society. It would be useful to have more local community consultation on planning and development and encourage service providers to take more responsibility.

January 2022