The DWP HB Review: Reviewing and/or re-modelling

your services

Danny Key

23 November 2011

Our Agenda Today

Background Context for Housing Benefit reform for Supported Housing

Analysis of the DWP ProposalsA Critique of the DWP Proposals: what do they

mean?Service Charge ReviewActivity since 9th October 2011How do Providers respond?

Review existing service delivery Re-model existing service delivery

Barriers to effecting change

Background Context to HB reform for Supported HousingPublic sector reform – public sector expenditure

cutsComplex regulations, administration &

interpretation – Turnbull factorNeed to keep pace with change of the supported

housing sector, i.e. development of supported living

The Welfare Reform agenda – Universal Credit

An Analysis of the DWP ProposalsIntended to remove bureaucracy and

streamline administration Categorisation of supported housing into 2

categories:Unregistered Providers (i.e. not RSLs/RPs)

1. Those providing short-term supported housing services (Foyers, refuges, hostels & sheltered housing)

2. Those providing longer-term “communal” services (for people with longer-term needs

Registered Providers (i.e. RSLs/RPs) irrespective of the type and duration of support provided – unless charges are determined as unreasonably high

A Critique of the DWP ProposalsMoney:

Unregistered providers (category 1: unregistered provider short-term services) will be paid Local Housing Allowance + a fixed top-up – possibly based on temporary accommodation arrangementsThis fails to recognise the high costs of such servicesMany such schemes will be rendered unviable

Unregistered providers (category 2: unregistered provider long-term services) will be paid Local Housing Allowance + top-up agreed at local levelAgreed by whom? – possibly whoever has responsibility

for care/support packages (Adult service/SP)

A Critique of the DWP Proposals

Will those administering the top-up understand the true costs of supported housing and/or the cost-benefits of prevention?

Will the costs be ring-fenced and/or capped?

Registered Providers:Existing rules apply, i.e. rents only referred if they

are deemed to be “unreasonably high”Rent Officers must compare like with like rather

than look at general market as per existing rulesWhat if they compare a Registered Provider (RP)

rent with that of an unregistered scheme that is subject to LHA + fixed amount?

Service Charge ReviewNot certain when this will happen....Liaising with CLG and Welsh/Scottish counterparts –

why? – should be bottom up rather than top down! “400 different service charges”!?

Actually far, far fewer but many of the same charges are given different definitions

DWP have however committed to funding the real cost of additional housing costs...whatever this means...

Potential to establish list of eligible service charges Important to pass the “reasonableness test” now with

regard to service charges prior to any changes in legislation.......

Service Charge Review......reasonableness test?....ensuring that you

review or re-model your existing services prior to the change in regulations to secure optimised/re-allocation of revenue

Therefore ensuring passporting of Housing Benefit awards for RPs

True cost recovery appears to only be available to RPs at present based on consultation proposals

What about non-RPs?

Activity Since 9th October 2011Very little!It has been identified that up to 200,000 people in

receipt of supported housing may have been discounted from initial research undertaken

It has been suggested that DWP will use the amount of HB payable to all exempt accommodation claims at date of change in legislation to create ring fenced budget – nothing to substantiate this suggestion however this policy would replicate the creation of SP budget

This policy would stifle development and potentially enable DWP to manage annual expenditure down just as occurred with SP budget

How do providers respond?Review existing service deliveryAnalyse service delivery based on activity

undertakenIntention to capture intensive housing

management activityRe-model service delivery to re-define

service as intensive housing management or enhanced housing management

What is Intensive Housing Management?

Ordinary housing management functions that are provided repetitively and intensively

Activity provided over and above ordinary housing management functions that would be provided to general needs social/private rented housing

Management, delivery and facilitation of housing services See Housing Corporation guidanceSee staff activity timesheet drafted with intention of

optimising housing management functions Define stand alone services, i.e. Day/night concierge/housing management officer

How is IHM an eligible service charge? Supported Housing Management Grant (SHMG) was defined to pay

grant to reflect IHM delivery requirements SHMG was transferred to Supporting People (SP) as a legacy

funding stream in 2003 SP does not usually pay for housing management No SP Grant conditions No local SP eligibility criteria – dependent on funding allocations Therefore a requirement to identify IHM Target rents don’t recognise IHM Service charges are defined in Housing Benefit law as, ‘a service

performed, a facility provided or a right made available’ IHM is a service performed and can therefore be established as a

service charge

Review existing service delivery

Analyse existing staff activity using IHM definition and guidance

Re-allocate costs based on findings where opportunity to optimise service charges and reduce support costs – adjust job descriptions

Particularly pertinent where SP Grant has been reduced

Re-modelling Service Delivery

Retention of scheme manager – always been an eligible service charge......it’s the activity that makes it ineligible or eligible

Re-allocate scheme manager to housing service charges from support

Provision of floating support service to those that require support Signposting is a function of intensive housing

management

Re-modelling Service Delivery

Creation of additional roles or redefinition of existing roles using IHM guidance to assist re-structure

Any new or re-defined service must be provided to ALL tenants as a condition of occupancy

Barriers to responding to HB reform changesLack of specific detail within HB reform

proposals – reacting to uncertain future Planning difficulty

Persuading Local Authority Housing Benefit departments to pay for IHM services

Non registered providers??Change management within the

service/organisation Consultation with tenants Consultation with staff

Registering with TSAMain benefit - favourable treatment by

Local Authority HB dept.HB Dept. receives full subsidy on all HB

claims paymentsRegistration process not particularly

onerous2 stage process

Preliminary applicationFull application

Registering with TSAPreliminary stage (to assess eligibility) – need evidence

that you; are an English body (not for profit OR for profit), that you provide housing and that the housing provided is ‘social’ (low cost rental

accommodation/shared ownership for ‘people not well served by commercial housing routes’)

Full application – Evidence to demonstrate how you do/will achieve the 6 standards (through co-regulation with tenants) Governance & Viability Client Involvement and Empowerment Homes

Registering with TSA Tenancy Neighbourhoods and community Value for Money

Our Contact Details

Fairgate House

205 Kings Road

Birmingham B11 2AA

0121 707 7766/8881

www.supportsolutions.co.uk

info@supportsolutions.co.ukTwitter @suppsolutions www.facebook.com/SupportSolutionsLtd?sk=wall

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