The DWP Review of Housing Benefit: reviewing and remodelling services for tenants with additional needs. This is 3 years old at time of posting in Slideshare: good advice doesn't age badly.
Artificial Intelligence in Philippine Local Governance: Challenges and Opport...
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