Written evidence submitted by Emmaus UK [EXA 084]
Emmaus UK represents a federation of 33 member organisations. Our members provide supported accommodation and meaningful work to over 800 formerly homeless individuals across the UK.
We welcome this review of exempt supported accommodation and the opportunity to contribute to this call for evidence. As providers of exempt accommodation, we feel it is essential that our sector has a strong reputation, that the issue of unscrupulous landlords taking advantage of the most vulnerable in society is addressed, and that high quality service provision is available to all. Our members are committed to continually improving the services we provide, and we would welcome the implementation of a quality and regulatory framework that improves the standards of accommodation and support provided to those in exempt accommodation.
The report ‘Exempt from Responsibility’ (2019) produced by Spring Housing Association, Housing Communities and Research Group (HCRG) and Commonweal Housing articulates well the current issues with the system, whilst also emphasising the important role that exempt accommodation can play in providing suitable, safe and successful housing. We would therefore urge any review of the sector and subsequent quality or regulatory framework to fully acknowledge this. Non-commissioned services make a significant contribution to addressing homelessness in the UK and we would hope that any system of oversight would recognise and respect the value of this diversity of provision.
We would also invite the Committee to consider the following points:
One of our members participated in a recent Supported Housing Quality and Oversight Pilot and was found to offer very strong levels of support and standards of accommodation. We would provide the following additional responses based on our experience of participating in that pilot.
As all costs cannot be recovered (see example below around support work) exempt accommodation is only financially viable if those essential support services can be funded separately, or sourced externally. We would prefer to see a full cost recovery model.
We feel that service costs will vary considerably based on the level and type of support provided and the geographical area the service is provided in. It is important that the service costs can be fully recovered, rather than being a fixed rate, and that providers are able to update their charges on an annual basis (as we can now) if necessary to reflect changing costs. We feel that the staff time allowed under the housing benefit claim needs to be broader than it is now to take account, not only of support provided directly related to a person's tenancy or licence agreement, but to also include the support provided around mental health or addiction for example, as this work is fundamental in helping that person to manage their tenancy or licence.
Having had an inspection as part of the Supported Housing Quality and Oversight Pilot our member would suggest that more regard needs to be given to client consent. We developed our own consent form as we did not feel that the consent process in place during the pilot adequately took account of GDPR and the rights of the data subject. The inspection was very time consuming, and as such, we think consideration needs to be given to inspection frequency as it will have significant resource implications particularly for smaller charities. We found the advice given by social workers during the inspection helpful and found it reassuring when we had completed the process and received positive feedback.
January 2022