PlaceShapers response to the DCLG and DWP consultation sets proposals to help sustain and develop supported housing for elderly and vulnerable people.

It responds to the 12 consultation questions and calls on the Government to abandon the Local Housing Allowance link and replace it with a national Supported Housing Allowance that would level the geographical differences and better reflect the true costs of provision. Read the full response here.

PlaceShapers vice chair Angela Lockwood said: “We are pleased that the Government recognises the importance of the funding of supported housing. However, the funding regime proposed falls short of what is needed and puts at risk existing and future provision. We recognise the need for a national framework and would support a workable, simple system that delivers certainty, fair outcomes and value for money alongside statutory duties to provide for existing and future demand at the local level. Regrettably, a local top-up of housing benefit as proposed does not achieve this. The metric used to set the LHA cap does not take into account the specialist nature of supported housing and the costs of developing and maintaining our assets. It creates major risks to existing and future provision, significant inequalities for service users and additional complexities and resourcing issues that will constrain value for money.”

The response clarifies that supported housing costs are broadly similar around the country. Linking their rents to the LHA would create variable funding gaps for similar cost schemes (with a particular North v South divide), would result in discriminatory outcomes for existing residents as a result of a postcode lottery approach to top-up funding and would act as a deterrent to the planning of new schemes other than in high-value areas.

The PlaceShapers call to abandon the LHA says that, providing the SHA was set at an appropriate level, this would require only limited top-up for approved higher cost schemes. The alternative option would be for the Government to accept that supported housing rents are by their nature higher than those for general needs tenancies and to agree that funding via the benefits system is paid at source at a higher level than the LHA rate where needed, without need for top-up applications.

Angela Lockwood said: “We have welcomed the opportunity to engage with the NHF, our local authority partners and others as well as Government on the need for a secure funding framework for supported housing and many of our members individually are contributing to this work. For the purposes of this formal consultation, we brought together a number of our key practitioners to discuss the questions posed together with their implications and help produce a collective PlaceShapers response. In doing so will set out in more detail their views on the proposed new funding system in the context of local services.”

The response also stresses:

• A major concern about the impact of the proposed system on older people who make up 71% of those occupying supported housing. This includes the hundreds of thousands of people living in sheltered housing whose rents tend to be lower than in other supported housing but will still be over the LHA level in large parts of the country. We do not believe that the Government intends to cause untold anxiety for older people by removing the certainty that their income will cover the costs of their home. Whilst we want to avoid a complex set of different arrangements, this is an example of why it is not appropriate to lump all so-called “supported housing” into one pot.
• It is not only sheltered housing that needs a different approach. All forms of non-permanent accommodation, including emergency hostels, require separate treatment. And specialised supported housing that has by definition been provided without significant capital subsidy needs to have a continued exemption within any new system. This category of accommodation is currently exempt from the rent setting framework and from the requirement to reduce rents by 1% per annum up to 2019.
• Long-term certainty for the future funding of supported housing does not mean a couple of years. Schemes are built with loan finance typically repaid over 30 years and the future protection of the thousands of vulnerable residents in them should not be subject to risk as Governments come and go.
• Local authority partners tell us that they do not have capacity to distribute the proposed top up funding. We are concerned therefore that unnecessary administrative costs will result and that this will not result in good value for money. Any reliance on LAs to make a new system work fairly must be accompanied by resources to cover transactional and implementation costs. The government has promised to retain the current level of investment in supported housing and any additional costs should therefore be met from outside current spend. There are parallels here with other policy areas where Government has accepted the need for additional resources, for example to enable LAs to implement duties in the Homelessness Reduction Bill when enacted. Additionally, there is a strong case for legislation to protect any agreed local funding pot given the trend for ring-fenced budgets to disappear. Without that, funds could be redirected by LAs to ease pressures on their ability to deliver other statutory services.