Written evidence submitted by YMCA St Paul’s Group [EXA 060]

About YMCA St Paul’s Group

YMCA St Paul’s Group is a long-established, highly regulated and quality provider of Housing, Care and Support to a wide range of young and vulnerable people across London. Our diverse housing stock ranges from large specialist supported housing to smaller properties that provide care for young asylum seekers and teenage parents.  

Alongside our social housing, we also provide a wide range of services to the communities where our accommodation is located. This includes access to health and wellbeing services, youth outreach programmes and providing early years activities for families from across the community.  

As a provider with more than 1,000 units of accommodation, we are subject to the same regulatory framework as many of the local housing associations. Given our smaller number of resources, we were pleased to be confirmed as a G1 V2 association by the RSH (Regulator of Social Housing) in early 2021. This regulatory judgement confirmed that we have strong governance, good risk management and a strategic direction that was owned by the Board and delivered by the staff. The V2 grade also confirmed we are compliant with the regulator's expectations but, as a specialist supported housing provider, we had lower margins.  

As a housing and community services provider we are already highly regulated, our regulators include: RSH, CQC, Ofsted, ICO and Charity Commission. We subscribe to a range of codes of practice including those from the NHF, Ombudsman, HSE, etc. We are also subject to frequent inspections and contract management reviews with the commissioning bodies (usually local authorities) where we have housing related support contracts in place. 

With all this in mind we are very keen to submit our response as an association to the consultation and happy to provide further evidence and information on request. 

What is the quality of exempt housing provision? 

We believe that the quality of exempt accommodation provision varies between providers.  

As a YMCA we currently provide exempt accommodation in over 30 different locations across London. Our stock varies from large hostel type buildings to smaller domestic properties.  

As a provider we place great emphasis on providing high quality accommodation that is safe and secure for our residents. Throughout the period of Covid restrictions we were able to maintain 100% compliance in our regulatory inspections as well maintain repairs.  

We are however aware that the quality of exempt accommodation varies, not least amongst those providers with fewer than 1,000 units of accommodation. We believe that there should be an enhanced version of the Decent Home Standard that focuses on ensuring there is an achievable, demonstrable standard that not only tracks the life cycle of assets but also the internal quality of the building that the resident is using.  

As well as the quality of the fabric of the building we believe that the quality of the support ranges significantly with many for-profit providers looking to generate a significant financial return by not providing the right amount and quality of care needed. We would therefore advocate for a position whereby both the quality of support and physical fabric are assessed.  

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

We believe that the vast majority of not for profit, registered providers do deliver a value for money service.  

As a YMCA we provide exempt accommodation to a wide range of young and vulnerable people. Some of our residents are referred through social services, others through homelessness units. As well as providing a roof over their heads we need to provide a range of wrap-around services including managing their mental and physical health, learning to budget and manage finances as well as managing any diagnosed issues they may have. Our staff often go beyond in helping people deal with their benefits, bidding for properties as well as gaining the necessary skills and qualifications to get them into work and permanent accommodation. This care and support is expensive, often complex and can be very time consuming as our staff are often required to help our residents navigate a range of external providers and support agencies.  

To deliver this service, following the removal of the ring fencing from Supporting People funding several years ago, we need to recover this cost in the intensive housing management from the eligible service charge. Over recent years we have seen the range and complexity of the needs of our residents increase but the thresholds through which they can access external services raised and become more remote (through digitisation). We therefore would advocate for the reinstatement of a protected ‘Supporting People’ type funding stream that would allow agencies such as ourselves to be able to provide the appropriate level of person-centred care that would enable residents, such as the ones we support, to be able to move on with confidence more quickly.  

Without exempt status this work would not be financially viable and the people we work with, who need that support, would not be able to find it. 

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

We are aware of the significant challenges in (for example) Birmingham - however these have not (yet) come to fruition in our areas of operation (London, Surrey, and Berkshire). This could be because of several factors, including property values and market rents being of high and increasing value - therefore a reduced yield for any prospective exempt accommodation providers in these areas. 

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

Exempt accommodation should be provided in close consultation with local authorities and in response to evidenced need. The total exempt rent charge (including service charge) should be linked to BRMA based limits. We believe that information on exempt rents must be made available publicly (whether for profit or charitable).  

Residents in exempt accommodation should be supported to pay the exempt rent charge when they enter employment, so that they are not penalised by taking on work, a circumstance that threatens to deter them from moving on. 

How should the regulatory oversight of exempt accommodation be organised? 

We believe that all providers of exempt accommodation should be not for profit and registered both with the Charity Commission and the Regulator of Social Housing. We would go further and state that exempt providers should also be listed with their local authority so that the quality of that accommodation is open to local security which can, if required, be escalated to the Regulator.

We have also observed smaller providers being targeted by developers offering lease-based accommodation to be used for exempt accommodation. This lease-based model via a third parties shifts the risk from the developer to the registered provider and threatens financial viability. We would advocate for increased education on the regulatory risks of this approach.

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

It is our view that the regulation of exempt accommodation should come through both the Regulator of Social Housing (with increased enforcement powers), the Ombudsman (with a closer working relationship with the RSH) as well as the Charity Commission (as stated above we also believe all exempt accommodation providers should be not for profit). 

At the same time we note that the RSH current grading is based on Governance & Viability we believe that the additional Safeguarding and customer care required for exempt accommodation means that the role of the Charity Commission and the Ombudsman are significant. Providers who do not comply with the requirements of these frameworks should be faced with deregistration and, in the case of serious breaches, disqualification from serving in similar roles in other likeminded organisations.  

Is there sufficient publicly available information about exempt accommodation? 

It is our experience that exempt accommodation has become an unhelpful catch all phrase which in reality describes a range of accommodation types. As such it is difficult to ascertain whether there is enough publicly available information.  

January 2022