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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 Proposals 
A Critique of the DWP Proposals: what do they 
mean? 
Service Charge Review 
Activity since 9th October 2011 
How do Providers respond? 
 Review existing service delivery 
 Re-model existing service delivery 
Barriers to effecting change
Background Context to HB reform for 
Supported Housing 
Public sector reform – public sector expenditure 
cuts 
Complex regulations, administration & 
interpretation – Turnbull factor 
Need 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 Proposals 
Intended 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 Proposals 
Money: 
Unregistered providers (category 1: unregistered 
provider short-term services) will be paid Local 
Housing Allowance + a fixed top-up – possibly 
based on temporary accommodation arrangements 
This fails to recognise the high costs of such services 
Many 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 level 
Agreed 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 rules 
What if they compare a Registered Provider (RP) 
rent with that of an unregistered scheme that is 
subject to LHA + fixed amount?
Service Charge Review 
Not 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 2011 
Very 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 delivery 
Analyse service delivery based on activity 
undertaken 
Intention to capture intensive housing 
management activity 
Re-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 guidance 
See 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 
changes 
Lack 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 TSA 
Main benefit - favourable treatment by 
Local Authority HB dept. 
HB Dept. receives full subsidy on all HB 
claims payments 
Registration process not particularly 
onerous 
2 stage process 
Preliminary application 
Full application
Registering with TSA 
Preliminary 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.uk 
Twitter @suppsolutions 
www.facebook.com/SupportSolutionsLtd? 
sk=wall 
20

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The DWP Review of Housing Benefit: reviewing and remodelling services for tenants with additional needs

  • 1. The DWP HB Review: Reviewing and/or re-modelling your services Danny Key 23 November 2011
  • 2. Our Agenda Today Background Context for Housing Benefit reform for Supported Housing Analysis of the DWP Proposals A Critique of the DWP Proposals: what do they mean? Service Charge Review Activity since 9th October 2011 How do Providers respond?  Review existing service delivery  Re-model existing service delivery Barriers to effecting change
  • 3. Background Context to HB reform for Supported Housing Public sector reform – public sector expenditure cuts Complex regulations, administration & interpretation – Turnbull factor Need to keep pace with change of the supported housing sector, i.e. development of supported living The Welfare Reform agenda – Universal Credit
  • 4. An Analysis of the DWP Proposals Intended 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
  • 5. A Critique of the DWP Proposals Money: Unregistered providers (category 1: unregistered provider short-term services) will be paid Local Housing Allowance + a fixed top-up – possibly based on temporary accommodation arrangements This fails to recognise the high costs of such services Many 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 level Agreed by whom? – possibly whoever has responsibility for care/support packages (Adult service/SP)
  • 6. 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 rules What if they compare a Registered Provider (RP) rent with that of an unregistered scheme that is subject to LHA + fixed amount?
  • 7. Service Charge Review Not 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.......
  • 8. 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?
  • 9. Activity Since 9th October 2011 Very 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
  • 10. How do providers respond? Review existing service delivery Analyse service delivery based on activity undertaken Intention to capture intensive housing management activity Re-model service delivery to re-define service as intensive housing management or enhanced housing management
  • 11. 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 guidance See staff activity timesheet drafted with intention of optimising housing management functions Define stand alone services, i.e. Day/night concierge/housing management officer
  • 12. 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
  • 13. 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
  • 14. 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
  • 15. 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
  • 16. Barriers to responding to HB reform changes Lack 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
  • 17. Registering with TSA Main benefit - favourable treatment by Local Authority HB dept. HB Dept. receives full subsidy on all HB claims payments Registration process not particularly onerous 2 stage process Preliminary application Full application
  • 18. Registering with TSA Preliminary 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
  • 19. Registering with TSA  Tenancy  Neighbourhoods and community  Value for Money
  • 20. Our Contact Details Fairgate House 205 Kings Road Birmingham B11 2AA 0121 707 7766/8881 www.supportsolutions.co.uk info@supportsolutions.co.uk Twitter @suppsolutions www.facebook.com/SupportSolutionsLtd? sk=wall 20