Written evidence submitted by Hull City Council [EXA 117]
Please note that Hull City Council officers have contributed to the Local Government Association (LGA) submission and Hull City Council supports the majority of the content of the LGA response. Additional Hull-specific information is provided below to complement the LGA response.
The experience in Hull is that the quality of exempt housing provision is varied. In Hull we have a dedicated Supported Accommodation Review Team (SART) with responsibility for oversight of non-commissioned supported exempt housing provision in the City of Hull. The Team’s findings in relation to property condition are set out below.
Inspection and Outcome stats from April 19 – January 2022
The Team has produced two annual reports covering more detailed information about the team’s activities, findings and outcomes. These can be provided upon request. In addition a log of tenant feedback and scoring of providers has been collated which again can be provided upon request.
Hull City Council is unable to comment generally on financial viability for providers in receipt of exempt rate Housing Benefit. There is however a specific case example in Hull of a provider getting into financial difficulty due poor demand for its high numbers of bed spaces which may indicate that in some circumstances the model is not viable where schemes are not developed based on local need.
From the work of the SART which has identified poor quality accommodation and support by some providers it does not appear that the level of funding provided through exempt rate Housing Benefit to those providers represents value for money.
We are unable to comment on this point however the LGA have addressed this within their response. We have a big challenge in Hull with the levels and quality of exempt accommodation.
The following data for the City of Hull was correct at 4 Feb 2022:
2687 bed spaces of supported (exempt) accommodation including commissioned and non-commissioned (of this total 1475 is classified by HB code as short-term)
1513 bed spaces are provided by Registered Providers which equates to 56% of provision all exempt provision.
Of the short-term provision (1,475 bed spaces) approximately 480 of these are commissioned by Hull City Council under Housing Related Support contracts which equates to 33% commissioned and 67% non-commissioned.
The work of the SART indicates that where a traditional Registered Provider provides exempt accommodation within their own housing stock, i.e. not under a lease model, the complaints are few and when they are raised the response from the Registered Provider is rapid and issues are resolved without the need for further intervention. This is in contrast to the picture generally for providers who are not registered as set out under question 1 above which largely represents providers who are not registered.
Where Registered Providers are operating a lease based model (an example from the housing regulator is here: https://www.gov.uk/government/publications/regulatory-judgement-parasol-homes-limited/regulatory-notice-parasol-homes-limited-15-december-2021) the SART have found poor housing conditions where this arrangement is in place.
In relation to commissioned vs non-commissioned we have not drawn a direct comparison between the two types of supported accommodation in Hull. Commissioned services are subject to robust contract management through the Quality and Performance Team and contractual action is taken to make improvements where any poor performance is identified under the contract. SART therefore does not oversee this provision and cannot operate in the same manner due to there being no contract to enforce for non-commissioned providers. A number of providers however have both commissioned and non-commissioned services so there is some crossover.
The LGA response is supported. In relation to cost – the sector is very diverse and a fixed cost model would not work because it must take account of the diverse needs of individuals and property types.
The LGA response is supported. In addition new provision or the expansion of existing exempt provision should be driven by evidenced need for that type; size; location; and model of provision. Local Authorities would be best placed to make an assessment of need and to publish a market position statement informing providers of the gaps in the local area. Demonstration that new provision responds to these gaps should be the first test within the gateway process.
The LGA response is supported.
The Department for Work and Pensions is in the process of finalising strengthened ‘housing benefit guidance for supported housing’ and has consulted with councils in its preparation. The Housing Benefit Service in Hull have been understandably cautious about making decisions on provision of supported accommodation based on guidance and generally revert to the regulations. Whilst strengthened guidance is welcomed, guidance remains open to interpretation, by both decision makers and Tribunals, and changes to the regulations and definitions are needed to address many of the key issues related to quality and costs.
Is there sufficient publicly available information about exempt accommodation?
The LGA response is supported.
February 2022