Written evidence submitted by Centrepoint [EXA 070]

About Centrepoint

Centrepoint is the leading national charity working with homeless young people aged 16 to 25. We are a registered social housing provider, a charity enterprise and a company limited by guarantee. Established 50 years ago, we provide accommodation and support to help homeless young people get their lives back on track.

Every year, alongside our partner organisations, we work with around 14,000 young people, providing tailored support to help them address their support needs, with a particular focus on health, learning, and move on to independent accommodation in both the social and private rented sectors. We also run a national helpline for young people at risk of homelessness.

About this submission

This submission has been put together in collaboration between Centrepoint and a range of partner organisations across England providing accommodation and support for vulnerable young people. Organisations were a mixture of registered providers and charities, delivering a mixture of commissioned and non-commissioned services.

Centrepoint organised a remote workshop to discuss the inquiry and its questions on 20 January 2022. This submission is informed by that discussion and consultation with partners, as well as discussion with Commonweal Housing.

Key points

• The ‘Exempt’ provisions within the Housing Benefit system provide a vital income stream without which many organisations would not be able to provide supported housing options for vulnerable young people, such as care leavers and those experiencing homelessness. This is especially true in the light of reduced local authority budgets and unstable external funding streams such as grants and charitable funding. 
• The lack of any formal regulatory body or scrutiny process enables poor providers to provide incredibly poor standards of service, which accentuates the vulnerability of the clients with whom they deal, whilst at the same time receiving a financial income stream to facilitate them in doing so.
• We welcome better regulation of the exempt accommodation sector as a way of raising and upholding standards for residents and ensuring that providers are held to account.
• However, we are cautious of the additional burdens new regulations and oversight measures could have on providers, particularly smaller providers, and would want to ensure that any new measures are proportionate.
• We feel that across the country, there is a lack of consistency in understanding and application of the current Housing Benefit rules and rules around exempt accommodation, and around the definition of what constitutes ‘more than minimal care, support and supervision’. We believe that clear and consistent national regulations could help address any regional differences which emerge and provide clarity to local authorities, providers and residents.

Key recommendations

• The introduction of a local authority-managed accreditation system (based on nationally agreed standards) to ensure providers meet the necessary standards of housing quality, support and governance, consistent across all areas to ensure consistency and reduce bureaucracy for providers working across multiple areas
• A comprehensive revision of the definition of “more than minimal care, support and supervision” that is a key condition of providing exempt accommodation as set out by the Department for Work and Pensions
• Ensuring the emerging consumer regulation for social housing - as outlined in the social housing white paper - includes specific standards relating to exempt accommodation, to meet the expectations over quality of standards that permit landlords to receive additional funds for delivery, and to better protect vulnerable residents

• What is the quality of exempt housing provision?

The quality of exempt housing provision is variable, and often dependent on levels of funding. In discussion with Centrepoint’s partnering organisations, we have heard of poor-quality providers utilising the exempt accommodation rules to provide accommodation of a poor standard and with minimal support. However, there are also some smaller non-commissioned exempt accommodation providers who are committed to supporting and safeguarding residents and who provide quality accommodation, who are concerned about being ‘tarred with the same brush’ due to coverage of more exploitative providers.

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

As above, the income from Housing Benefit under the exempt rules provides many providers with crucial funding to keep services running, particularly in light of reductions from other sources such as Supporting People and wider local authority budgets. Many partners also reported supporting their services through charitable funding, in order to meet costs not covered through the benefits system and to deliver the quality they think is needed. We believe that maintaining funding for exempt supported accommodation through the benefits system – rather than through block grants to local authorities, or personal budgets - does provide a level of stability for providers although we appreciate that oversight is needed to ensure that this approach is not open to abuse.

Where exempt accommodation is providing quality accommodation and support, we believe that it is providing value for money by relieving pressures on wider public services and supporting residents’ development and independence. However, we agree that where providers are not providing a sufficient standard of accommodation and support but are receiving higher housing costs through the benefit system, this represents both poor value to the taxpayer as well as a failure to provide vulnerable individuals with the support they need.

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

There are many factors which can affect the provision and quality of exempt accommodation, such as availability and size of local housing stock, level of need, and the provision of other services in a particular area. However, one factor discussed by Centrepoint’s partners leading to geographical differences is the difference in approach taken by local authorities. For example, one provider working across several different local authority areas highlighted that they had worked in a particular area where the authority seemed to make no attempt to verify that any support was being provided beyond the submission of housing benefit returns. At the other extreme, the provider also highlighted that there had been another local authority in which local oversight had been onerous to the point that they felt it was not feasible to continue providing accommodation services.

A key concern was around the lack of uniformity or consistent approach to managing exempt accommodation or applying housing benefit regulations, and that this could lead to ‘less scrupulous’ landlords and providers looking to exploit areas where oversight was seen as more light-touch. There is thought to be significant variation in the interpretation of certain costs and no guidance on benchmark figures, enabling unscrupulous providers to take advantage of this lack of structure and clarity, and cost things in a way which simply does not represent the cost born to themselves nor the service provided to their clients; they are not held to account for this.

Centrepoint therefore believes that clear and consistent national standards would be useful to ensure greater consistency across the country.

• What is the proportion of exempt accommodation that is provided by registered compared to non-registered providers, and is an appropriate balance being struck?
• What is the proportion of exempt accommodation provided by commissioned compared to non-commissioned providers, and is an appropriate balance being struck?
• How does whether a provider is registered or non-registered, or commissioned or non-commissioned, impact the quality of provision?

We are not aware of the exact proportion of accommodation which is provided by registered versus non-registered providers, nor the proportion of commissioned versus non-commissioned services. Our own partnering network and the organisations which fed into this response are a mixture of registered providers and charitable organisations, and a mixture of commissioned and non-commissioned services, with some providers operating both. Local authorities and officials within DWP and DLUHC may be better placed to access this information.

Centrepoint does not believe that a providers’ status as registered or commissioned is necessarily indicative of quality as many smaller non-commissioned services do provide high quality support to young people. Several partners have also mention barriers that exist around becoming a Registered Provider, namely the costs and additional reporting requirements, and the fact that smaller providers reliant on charitable and grant funding may struggle to meet the financial viability requirements of the Regulator of Social Housing. For this reason, while the regulation of exempt accommodation may be overseen by the Regulator of Social Housing, we do not believe that becoming a registered provider should be a necessary precondition to delivering supported accommodation.

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

Exempt accommodation should be provided by providers committed to the safety and wellbeing of vulnerable people. We believe that many of the problems that exist within exempt accommodation are related to a wider lack of funding for services, reducing the capacity of good providers and allowing less scrupulous providers to fill the gap.

One example of good practice in supported housing is Centrepoint’s HOMES model. This model aspires to deliver the best possible service to residents, such as through meeting high property and maintenance standards and providing staff with the training needed to deliver quality, psychologically informed support. However, Centrepoint has the advantage of being an organisation with a national profile and commissioned services across England, which smaller providers will not have. By properly resourcing local authorities and restoring funds such as Supporting People, quality providers of all sizes can be supported to deliver the accommodation and support needed by vulnerable groups.

• How should the regulatory oversight of exempt accommodation be organised?

A register of exempt accommodation providers should be established, reviewed by local authorities. We believe that developing capacity within the Regulator of Social Housing to support local authorities to manage exempt accommodation locally would help provide national consistency and mean that less scrupulous providers could not simply move to a new area.

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

We believe that the regulations governing exempt accommodation need to have the safety, wellbeing and development of exempt accommodation residents and service users at their heart. We have heard from partners that the current loose understanding of what constitutes more than minimal ‘care, support of supervision’ can often fail to take into account the different support needs of individuals and client groups.

If new regulations for exempt accommodation are proposed, we feel these must take into account residents views and priorities, through effective consultation and opportunity to feed into their development. 

We believe that oversight and enforcement should occur at a local level, by professionals who are aware of the local context and provision. Regulations could be enforced by local authorities, supported by a national regulator, with the opportunity for providers, residents and advocacy groups to raise issues directly with the regulator. We also feel that lessons can be learned from similar regulatory frameworks, such as the DfE’s new national standards for supported accommodation for 16 and 17 year olds. Ideally there should be as much consistency with these as possible and practical to make it easier for services operating across both sectors.

• Is there sufficient publicly available information about exempt accommodation?

We do not believe there is currently enough information about exempt accommodation. Feedback from partners suggested that it is difficult for the public to access information and that many of the terms and definitions used in this area are highly technical, making them harder to understand and scrutinise on a local level.

January 2022