Written evidence submitted by the Riverside Group [EXA 080]
2.1. The Riverside Group Ltd (referred to as Riverside) is one of the largest charitable housing association groups in the country. Following the merger with One Housing in December 2021, we now own and manage over 75,000 homes.
2.2. Riverside has a strong supported housing business, and with over 5,500 homes we are the largest housing association provider of supported housing for rent in England. The provision of housing support to some of the country’s most vulnerable households is central to our mission.
2.3. We welcome the opportunity to submit evidence to the Levelling Up, Housing and Communities Committee inquiry into exempt accommodation. We have not attempted to address every question but have focused our evidence on two specific question which are most relevant to our work.
2.4. Exempt accommodation is a broad term, covering the majority of supported housing where support services are provided or commissioned by a housing association or other not for profit landlord. The majority of our supported housing fits this definition of exempt accommodation.
2.5. However, the term ‘exempt accommodation’ has also come to be associated with a much narrower segment of the supported housing sector – where mainly lease-based models have been used to provide housing, allegedly at high cost and low quality, outside the scrutiny of any regulatory or commissioning frameworks. It is this narrower issue that we address in our submission, focussing on how to distinguish it from mainstream supported housing, and ensure appropriate quality and value mechanisms are in place.
Q: How should the regulatory oversight of exempt accommodation be organised?
3.1. Riverside believes that the majority of exempt accommodation and associated housing services provided by housing associations which are Registered Providers is of high quality. It is essential in providing suitable accommodation which can act as a basis for the provision of support for those who need it on both a short- and long-term basis, and is vital in preventing homelessness.
3.2. Most supported housing provided by Registered Providers is considered to be social housing. As organisations, social housing providers are already appropriately regulated in terms of their governance, viability, and value for money, with rents set in accordance with a detailed rent standard and guidance. The Regulator of Social Housing has already shown it is prepared to use these economic regulation powers to deal with some registered providers engaged in high-risk models to deliver exempt accommodation, and this has been a matter of significant focus for them.
3.3. In a further move to protect social housing tenants, the regulatory framework around consumer standards (overseen by the Regulator of Social Housing) is in the process of being strengthened, and a new proactive approach to consumer regulation should provide additional assurance about the quality of accommodation and housing services, including for exempt accommodation where it is provided by a Registered Provider. Indeed, as the details of a new set of consumer standards are developed over the coming year, there is an opportunity to ensure that they are sufficiently robust to safeguard quality in the supported housing sector.
3.4. Whilst social housing regulation is concerned with the provision of housing and housing services (as opposed to care and support services) – in the same way that ‘exempt accommodation’ is a term that relates to housing and associated services, it being derived from housing benefit regulations – most supported housing in the social housing sector (the vast majority in the case of Riverside), houses tenants who benefit from care and support services which are ‘commissioned’, usually by a local authority. This provides an additional layer of scrutiny and quality control, albeit in relation to the support services as opposed to the accommodation.
4.1. As a strongly governed organisation, Riverside, like many social housing providers, has robust internal quality control mechanisms. Our Quality Management System is accredited to ISO 9001:2015 standards and our internal audit process in our Care and Support Division forms the basis of this. Utilising audits by a dedicated central team, in tandem with a comprehensive peer audit schedule, we ensure that our services are delivered to the highest standard met through continuous monitoring, review and improvement of activities.
4.2. The internal audit tool is used to record compliance with policies and procedures, adherence to local and national procedures, staff and management knowledge and customer experience. Timely follow up action plans ensure consistent high quality service delivery.
Q: What should be the regulations governing exempt accommodation and how should those regulations be enforced?
5.1. We are aware that there have been concerns expressed about the quality of accommodation and services of some non-regulated providers, and in a limited number of cases, Registered Providers who have exploited regulatory ‘loopholes’. Whilst we have limited experience of these types of providers and services, and others are better placed to provide evidence, in general terms we believe there is a case and would support additional measures to improve quality and value for money for these providers and the services they deliver to hold them to a similar standard as Registered Providers.
5.2. We believe that for providers of exempt accommodation who are not Registered Providers, a system of mandatory accreditation should be introduced as a condition of their homes achieving exempt accommodation status. As a minimum this framework should set out the standard of accommodation that should be provided (for example it should meet the Decent Homes Standard) and standards for the provision of tenancy management and support services. This should, in the main, be paid for by those providers through an accreditation fee, with Government top up to meet the cost of additional burdens where this is not sufficient.
5.3. Whilst the better application of housing benefit regulations may be a helpful tool, on their own they are not sufficient as a mechanism for driving better quality and value in regulating this part of the sector as they tend to be used reactively. Further it is not appropriate to place the burden of oversight of exempt accommodation on housing benefit teams who do not have the right tools, resources and skill sets.
5.4. We believe that such an accreditation framework would be best implemented by local authority teams with the right mix of skills and resources. These might be multi-disciplinary teams with experience in private sector housing, benefits and care and support - drawing from the experience of the recent exempt accommodation pilots.
5.5. Providers who are already regulated (registered providers, local authorities) should not be included in this method of accreditation, in order to avoid double regulation and an undue burden being placed on them.
6.1. In conclusion, we believe that well-run exempt accommodation provides an essential service to those with support needs and can reduce the risk of homelessness. Any changes to its oversight and regulation should be focused on non-regulated providers, setting out clear minimum standards for accommodation and services to meet the needs of tenants with support requirements through a clear targeted accreditation mechanism focused on value for money and quality.
6.2. Any changes must avoid adding to the burden of regulation placed on Registered Providers.
January 2022