Written evidence submitted by Mayors of West Midlands, North of Tyne, Cambridgeshire and Peterborough, Liverpool City Region, Sheffield City Region, West Yorkshire, and West of England [EXA 112]
The following is a joint response from Andy Street, Mayor of the West Midlands; Jamie Driscoll, Mayor of North of Tyne; Nik Johnson, Mayor of Cambridgeshire and Peterborough; Steve Rotheram, Mayor of Liverpool City Region; Dan Jarvis, Mayor of Sheffield City Region; Tracy Brabin, Mayor of West Yorkshire; and Dan Norris, Mayor of the West of England.
We welcome this Inquiry into the challenges related to non-commissioned exempt supported accommodation and the opportunity to respond.
Over recent years we have become increasingly concerned with the significant growth in exempt accommodation provision across our regions. Nationally, FOI information published by Crisis in October 2021 demonstrated that 153,701 households in Great Britain were housed in exempt accommodation as of May 2021. This represents a 62% increase from 2016 to 2021.[1]
We know that the quality of exempt accommodation varies. There are good providers who work positively with Local Authorities, using the rent model to meet accommodation needs, invest in good quality accommodation and help tenants to overcome barriers and move on. However, there are an increasing number of providers who exploit the model to quite simply generate significant income, paid for by central government. The quality of many of these properties fall far below standards, putting tenants at risk and trapping some of our most vulnerable citizens in some of the poorest housing, without adequate support and move on options.
Prospect Supported Housing recently published a report on their decision to close exempt accommodation provision. They estimated “that at least £816m has been spent on exempt accommodation in the last financial year alone. This is based on the responses received and a conservative estimate for those who were unable to provide exact figures”. They went on to note: “Spend on exempt accommodation (and presumably demand) has continued to rise. Based on responses from 52 authorities, the spend on exempt accommodation has risen by over £110m between 2018-19 and 2020-21”.[2]
The 5 national supported housing pilot areas have taken a lead in addressing this issue. The emerging learning and recommendations from this work are welcomed. However, there remains key gaps. Current regulations rely heavily on outdated housing benefit regulations and make it extremely difficult for Local Authorities to manage the supply and quality of exempt accommodation provision. Therefore, we are of the view that guidance is no longer adequate to address this proliferating issue.
We support the proposals made by those involved in the pilots and their partners and
suggest that the regulations governing exempt accommodation should include:
- A review of the current funding model for locally delivered supported housing – incorporating funding of support for vulnerable tenants and resources for Local Authorities to enable any new duties and responsibilities concerning regulation, planning and commissioning to be carried out effectively.
- Consideration of a government national accreditation requirement for providers, supported with additional regulation to enforce this and a national database of providers’ performance against these standards.
- Oversight of the provision and development of supported housing to be within the remit of Local Housing Authorities, based on a duty to assess the local need for supported housing and development of a supported housing strategy, which meets local need and includes those who cannot remain in their local areas, for example refuge provision.
- For local authorities to have greater tools, authority, and ability to control provision and growth based on their needs assessment. These would mark a substantial step change in Councils' ability to stop or restrict growth, based on market saturation or oversupply.
The key requirements are:
○ Alignment of existing planning and HMO licencing powers to capture supported housing provision – currently exempt from licencing, Article 4 etc. to assist in managing supply.
○ Strengthened definitions within current regulations relating to the level of provision of care, support, and supervision.
○ Consideration of the scale of provision and ratios of support workers to vulnerable residents they are supporting, and the source of funding for support to be transparent.
- Strengthen the role of the Regulator for Social Housing role and ability to effectively monitor compliance against consumer standards for RPs in this sector. Including and especially, where providers operate a leased based model for the provision and supply of accommodation and support.
- Strengthen the role of non-RP regulators including within the Charity sector to ensure proper oversight of quality is in place.
- Protocols put in place for statutory referring agencies into Exempt Accommodation to create greater consistency and accountability for out of area placements.
- Greater enforcement powers to tackle providers who do not effectively manage Anti-Social Behaviour, including additional Community Safety powers.
This Inquiry offers a key opportunity for government to introduce a robust regulatory framework that ensures the current funding for this unacceptable housing provision is invested in a way that provides better outcomes for our citizens and contributes to levelling up the regions we represent.
Yours sincerely,
|
Nik Johnson
Mayor of Cambridgeshire and Peterborough
|
Jamie Driscoll
Mayor of North of Tyne
Steve Rotheram
Mayor of Liverpool City Region 
Dan Jarvis
Mayor of Sheffield City Region
Tracy Brabin
Mayor of West Yorkshire
Dan Norris
Mayor of West of England
Andy Street
Mayor of the West Midlands
February 2022